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Privacy Policy for Homely NewCo(‘Policy’)
Navigation
1: Who we are.
2: How to contact Homely about your Personal Data?
3: Scope of this Privacy Policy and changes.
4: What are your rights?
4: Withdrawing consent.
6: Personal Data we collect about you.
7: Sources of Personal Data.
8: How we use your Personal Data.
9: Storage of your Personal Data.
10: Disclosure of your Personal Data.
11. Change of Purpose
12: Contact
13: Complaints.
1. Who we are
1.1 Homely Newco, a company registered in England and Wales under company number 16522536 and having its registered office at The Edge Business
Centre, Clowes Street, Manchester, M3 5NA. (“We”, “our” and “us”)
1.2 We are committed to protecting and respecting your privacy. We will only process or otherwise disclose your personal information as described in this
Policy.
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1.3 We operate under a number of the trading name of Homely.
1.4 For the purpose of the UK GDPR and the Data Protection Act 2018, the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU
Exit) Regulations 2019 and any supplementary, subsequent or secondary legislation and regulations, Homely is the data controller for your personal data, as
set out in this Policy.
2. How to contact Homely about your Personal Data?
2.1 Questions, comments, issues and requests regarding this privacy policy or your data are welcomed and should be addressed
to team@homelyenergy.com
2.2 The Edge Business Centre, Clowes Street, Manchester, M3 5NA.
2.3 Telephone: +44 (0) 161 818 9005
3. Scope of this Privacy Policy and changes
3.1 This Policy aims to give you information on how we collect and process your personal data through your use of our websites (see 3.2), including any
data you may provide when purchasing or receiving our services, when registering an account or profile on our websites; downloading our Apps; when
using our websites or when you communicate with us; when you sign up to any newsletter or email list; or when you enquire about our services or
products. This policy also set out when we may communicate with you in relation to our services, products and business, as well as the data we need to
process in order to provide our services and products.
3.2 As with all our policies, we may revise and update this Policy from time to time, and any updates will be placed on homelyenergy.com. Please refer to
this websites regularly to check any changes and updates to this Policy.
3.3 This websites and our Apps (including the Homely Mobile App) are collectively and individually referred to throughout this document as “the Website”.
The Website is not intended for children and we do not knowingly collect data relating to children.
4. What are your rights?
4.1 Homely recognises that your personal data belongs to you and we don’t wish to use it in ways that you don’t want us to.
4.2 You can control whether or not you receive marketing email by using the “opt-out” button at the bottom of the email. We will only send these to
consumers and individuals with your consent or if you are an existing customer (see Marketing (8.2) below for more details)
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4.3 Please note that you have specific rights under data protection law in relation to the use of your data, including the ability to regulate and/or object to
our use of your data.
4.4 You have the right to object to our processing of your data in some circumstance, including where:
• Processing is based on legitimate interest;
• Processing is for the purpose of direct marketing;
• Processing involves automated decision-making and profiling.
4.5 You can also exercise a variety of rights regarding our use of your data:
• You can ask us for a copy of the information we have about you (usually free of charge)
• You can request an explanation of decisions regarding the processing of your information.
• You can ask us to correct any incorrect data we have about you by emailing or through communication with your point of contact at Homely. You
may also be able to correct any data directly through your profile or account on our Website or App, if you have one.
• You can ask us to delete your data.
• You can ask for your data in a common, machine-readable format.
• You can object to any processing we do on the basis of legitimate interests or to any automated decision-making, for example when your employer
is a supplier or customer or supplier of ours.
• object to us processing your personal data for direct marketing purposes even if you have previously given consent. You can do this by emailing
Please note we will balance any request to assert the above rights with other legal requirements and permissions in relation to the processing and
retention of personal data; for example, the need to protect other individual’s personal data, to perform a contract with you, to meet a legal reporting
requirement or because we have a compelling legitimate interest which we have determined to outweigh the above rights.
4.6 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
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contact you to ask you for further information in relation to your request to speed up our response. Please contact us at team@homelyenergy.com if you
have any queries.
4.7 Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could 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.
4.8 Links:
Our Website 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.
5. Withdrawing your consent
5.1 Where we are processing your personal data based on your consent, you may change your mind and withdraw your consent at any time. You can
withdraw your consent to receive marketing communications by clicking on the opt out/unsubscribe link in an email or by adjusting the push message
settings for the mobile application. You can also withdraw your consent to receive marketing communications or any other consent you have previously
provided to us by contacting us at or advising a representative of Homely on the phone.
6. Personal Data we may collect from you
6.1 We may collect and process the following personal data about you:
• name;
• address;
• email address;
• telephone number;
• address
• business name
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• account number
• job title
(If you work for or are otherwise subcontracted to one of our business customers, the above information is collected in order to provide the
service to your employer. This information is also required in order to be compliant with regulation.)
• information about any device you have used to access our Services or the websites, or download an App (such as your device’s make and model,
device identifier, operating system, browser, MAC address or IP address);
• information about the pages or sections you have visited on the websites including the pages or sections you visited, the website or mobile
application you were referred from, and when you visited or used them;
• information about the Services we provide to you (including for example, what we have provided to you, when and where and, if applicable, how
much you paid);
• bank account details, payment card information, and information from credit reference agencies;
• your account login details and profile information when you register an account with us, including your user name and password;
• information you provide to us with when you contact us by phone, email, post, or when you communicate with us via social media;
• information about electronic communications you receive from us, including whether that communication has been opened and if you have clicked
on any links within that communication;
• answers you provide when you respond to competitions, votes and surveys;
• your identity, public profile, follows and likes from a social network such as Facebook (this may include your employment or education information
if you include it in your public profile);
• your use of your Homely Hub and heating system, information on the performance of your heating system, faults in equipment, patterns of heating
behaviour and absences from the property, all for the purpose of monitoring your heat system;
• other personal data which you may disclose to us when you use our Services at any time.
We also collect, use, retain and share anonymous or aggregated data ‘Aggregated Data’ such as statistical or demographic data for any purpose.
Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your
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identity. For example, we may aggregate data on how you use our Website to calculate the percentage of users accessing a specific website feature, or to
better understand how our products function and heating systems operate more widely. However, if we combine or connect Aggregated Data with your
personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.
Sensitive Data (known as Special Categories of Personal Data and includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual
orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We do not usually collect this
Sensitive Data about you and will obtain your explicit consent in the event we intend to.
7. Sources of personal data
7.1 We will receive your personal data when you provide them to us yourself.
Direct interactions. You may give us your Profile, Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email
or otherwise. This includes personal data you provide when you:
• purchase and receive our services and/or products, including our subscription services;
• create an account for one of our services or Website;
• purchase and use or install one of our products
• download an App;
• you enquire about or purchase services/products on behalf of your employer/business;
• enquire about or discuss our services and/or products;
• subscribe to our newsletter or mailing list;
• request marketing to be sent to you;
• respond to a survey or provide feedback;
• through connectivity with your Homely Hub.
Automated technologies or interactions. As you interact with our Website and Apps, we will automatically collect Technical Data about your equipment,
browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for
further details. We may also collect information on your heating system use and performance via our Apps and/or Homely products.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below.
• From your employer if they are a supplier or customer of ours;
• From a member of our household if they have been given access to your Homely Account;
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• From banks, financial institutions and payment processing facilities;
• Credit Check providers, Companies House and any other agreed third party references;
• From our industry regulators and Government bodies;
• Technical Data from analytics providers such as Google based outside the EU;
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
• From our manufacturers, suppliers and subcontractors where they directly supply goods or services to you, so that we may control, oversee and
manage the supply of these to you;
• From a heating system installer or engineer who you have given permission to access heating system data via Homely Connect.
7.2 Where we have engaged a sub-contractor to perform some of the services to you, they may collect some personal data whilst performing such services
and this will be given to us (see also section 10 below Disclosure of your Information).
8. How we use your Personal Data
8.1 All personal data that we obtain about you will be used in accordance with current data protection law and this Privacy Policy. We will process your
personal data as follows:
• As necessary, to meet our obligations under any contracts you are a party to (or your employer or main contractor is a party to), such as a
contract to process an order from you for one or more of our Services or products including, where applicable, taking payment and carrying out
support services and delivery.
• As necessary, to comply with a legal obligation, for the following purposes:
• Where you exercise your rights under data protection law and make requests.
• To report to our regulators.
• To provide and maintain tax and accounting records.
• Based on your consent, for the following purposes:
• To send you marketing communications (also see 8.2 Marketing).
• To refer to third party partners in relation to their goods and services.
• To share data on your heating system performance and faults with an engineer/installer approved by you.
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Based on Legitimate Interest. We may process your personal data for the purposes of our legitimate interests, provided that these uses aren’t outweighed
by your rights or interests. For any uses we justify on the basis of legitimate interest, you have the right to opt out of such processing. These include the
following:
• We may contact you for marketing purposes (see 8.2 Marketing).
• We may review and assess your use of our services in order to better understand our business and services, as well as develop new products.
• To set you up as the key user or administrator for your employer
• To manage or accounts and tax reporting.
• To manage and support our CRM and business functions, supply chain and subcontractors.
• To operate and maintain our Website and portal, to provide updates and new versions and ensure their performance.
• To operate and maintain our apps and ensure their performance;
• To monitor the operational performance of your home heating system;
• To manage our supply chain when the supplier, logistics provider or other subcontractor directly delivers goods to, or performs services for, you;
8.2 Marketing
• If you are an individual or consumer we will only market to you if you have provided your consent, have requested information from us or
purchased services from us and you have not opted out of receiving that marketing.
• We do contact and market to existing business customers and other organisations which we believe may be interested in our services and, as such,
may contact you using your business contact information in order to discuss this with you or your employer. We rely on our legitimate business
interests to do this.
• Nonetheless, we strive to provide you with choices regarding any marketing communication and you will be able to opt out of any communications.
If you opt-out we operate a suppression list to ensure we can manage this process, which means we keep the minimal personal data necessary to
ensure we do not contact you again.
• Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of service purchase or
other transactions, or when we have another legal basis to process.
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• We do not share your data for third party marketing without your consent.
Please see the below table for more details on key examples of the data we process, how long for and who it may be shared with.
Data Shared With
Data
Collected Purpose for Collection
Lawful Basis for
Processing Retention Period
Cloud-based CRM system
Name,
Company
name,
geographic
location,
email
address, job
role, Contact
No.
To provide accurate Customer Relationship
Management records for our Customer base
and to ensure we are providing a high level
of service to our customers through
understanding their requirements.
To communicate with you about any issue
that you raise with us or which follows from
an interaction between us
Contractual fulfilment/
Legitimate Interest
Retain indefinitely whilst the Customer is
in contract with Homely or 2 years post
contract/consent
Dial Pad and Chatra
Telephone
number /
Business
Name /
Customer
Name
To ensure that all calls are recorded for
training and quality purposes. To ensure that
we can deal with all Customers enquiries and
ensure a high level or service
To communicate with you about any issue
that you raise with us or which follows from
an interaction between us
Legitimate interest
3 years
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Data Shared With
Data
Collected Purpose for Collection
Lawful Basis for
Processing Retention Period
Analytics tools - Google
Analytics, Facebook Pixel,
Hotjar
Name / Email
Address /
Contact
number -
provided
through
website
forms or at
trade shows
or any other
means.
Primary
account
number
(PAN),
cardholder
name, service
code,
expiration
date
In order to be able to contact
customers/potential customers who are
interested in a product or service provided
by Homely
Consent
6 months if a marketing mail is left
unopened
Stripe/Jooma/ Sage Pay
Name,
physical
address,
email
To process purchase / service transactions
for products and services with customers,
and to ensure any transaction issues can be
dealt with.
Contractual
performance /
Statutory
Maximum 8 years from the date of the
performance of the contract
8 years for VAT records from the
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Data Shared With
Data
Collected Purpose for Collection
Lawful Basis for
Processing Retention Period
address,
telephone
number,
bank account
details (for
automatic
renewal of 12
monthly
subscriptions)
To fulfil purchase requests using payment
cards
For accounting and taxation purposes
Documentation should any contractual legal
claim arise
Obligation/legitimate
interest
performance of the contract
(Note: Full card information is never held
in the system in line with PCI / DSS
Compliance)
CloudFlare
Technical
information,
Name /
Address /
Contact
information
To protect our websites and infrastructure
from cyber attack or other threats and to
report and deal with any illegal acts
Legitimate interest
Duration of use of service
Homely (hosted on AWS)
All types of
personal data
referred to in
6.1 above or
otherwise
As a secure cloud hosting service in which
relevant information on customers, product
and service information, heating system
performance, customer profile and
preferences, and other personal data
processed by the business is stored in
accordance with this Policy.
Legitimate interest/
contract/consent
For the duration of any service,
engagement or interaction, and for up to 6
months after, unless we otherwise are
required or permitted to retain it longer
(for example if managing a complaint or
for tax/payment records) in accordance
with the purpose the data was collected.
Aggregated/anonymous data may be
retained as set out in 6.1. above. For
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Data Shared With
Data
Collected Purpose for Collection
Lawful Basis for
Processing Retention Period
further information on retention practices
for a specific data category, please contact
us.
MailChimp
Name / Email
Address /
Phone
Number
We collect your name and email address to
send you to information about updates
relating to:
(i) registration and
account services;
(ii) Contacting you
in relation to
service
provision, our
services and
products, and
account
management;
(iii) our newsletter;
(iv) Other business
and customer
management
communications.
Consent/legitimate
interest
Whilst the customer, their employer or
main contractor is an Approved
Organisation or otherwise has a contract in
place with Homely, Easy MCS/Green Deal
or chooses to opt out of newsletters.
Not retained if individual rejects validation
email as part of registration process for
their employer or main contractor with
Homely.
NOT completed funding calculator (didn’t
click link) - Keep data for as long as re-
targeting sequence lasts.
Opted in to send results but NOT booked
an assessment - 18 Months
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Data Shared With
Data
Collected Purpose for Collection
Lawful Basis for
Processing Retention Period
(v) Marketing and
other
communications
as permitted in
accordance with
this Policy.
We collect your
name, email
address in order
to maintain
contact with you
about your
enquiry for our
products and
services
Opted in to send results but NOT booked
an assessment - 18 Months
NOT Opted in to send results and NOT
booked an assessment but completed
funding calculator - 18 Months
Assessment Carried out and Data Collected
and Stored in the Installer Toolkit - 7 Years
Website Contact Forms
Name / Email
Address /
Contact
Number
We collect your name, email and telephone
number to provide you with your requested
information about our products and services
Consent
2 Years, unless you, your employer or main
contractor becomes a customer in which
case it may be longer, in line with the
above retention periods.
With manufacturers, third
party suppliers, logistics
providers and sub-
Name and
identity data;
address,
In order to manage the delivery of products
to you (as well as returns, replacements,
collections and refunds) and ensure
Legitimate interest;
Contract;
Up to 8 years for VAT records from the
performance of the contract. Or two years
if on the basis of your consent.
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9. Storage of your Personal Data
9.1 Homely is a UK based organisation whose offices are in the UK.
• Our Website is hosted within the UK or the EEA.
• Our customer relationship management, marketing and accounting systems for all our businesses are UK and EEA based.
• We use a wide range of Cloud Service Providers (CSPs) as part of our processing environment. Unless we specifically state otherwise, we are, in
respect of all these CSPs, the data controller.
• Unless we specifically state otherwise all of the CSPs that we use utilise UK or EEA-located processing facilities.
Data Shared With
Data
Collected Purpose for Collection
Lawful Basis for
Processing Retention Period
contractors providing
services and supplying
products on our behalf.
(specifically including
Dantom who
manufacturer Homely
products)
email and
contact data;
information
on products
and services
purchased.
Information
on the use
and
performance
of your
heating
system.
contracted services are performed as agreed,
products purchased are operating correctly,
we may need to process personal data and
share it with our supply chain.
Consent
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• Our payment processors and banking arrangements are based in the UK or EEA
9.2 The data that we collect from you may be transferred to, and stored at, a destination outside the UK and European Economic Area (“EEA”). Whenever
we transfer your personal data out of the UK and the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following
safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK
Government (which is deemed to include the European Union post Brexit).
• Where we use certain service providers, we may use specific contracts approved by the UK Government which give personal data the same
protection it has in UK as well as undertaking appropriate due diligence and risk assessment of that service provider and local laws.
9.3 We may also transfer your data outside of UK without one of the above safeguards (9.2) on an occasional basis with your consent or to perform a
contract with you.
9.4 Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Website, you are responsible for
keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the Internet is not
completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website.
Any transmission is therefore at your own risk. Once we have received your information, we will use strict procedures and security features to try to
prevent unauthorised access.
10. Disclosure of your Personal Data
10.1 We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its
subsidiaries, as defined in Section 736 of the UK Companies Act 1985.
10.2 We may disclose your personal information to third parties:
• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such
business or assets.
• If our business or substantially all of its assets is acquired by a third party, in which case personal data held by us about our customers will be one of
the transferred assets.
• If we are under a duty to 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 with you.
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• To protect the rights, property, or safety of us, our customers, or others.
• If we need to disclose personal data to one of our sub-contractors and suppliers who may be providing the services or products directly to you,
however, please note we ensure we have appropriate safeguards in place with these sub-contractors.
• To other third parties with your prior consent, such as an approved installer with access to your heating system and Homely Hub data.
11. 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 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.
12. Complaints
12.1 Should you wish to discuss a complaint, please feel free to contact us using the details provided above. All complaints will be treated in a confidential
manner.
12.2 Should you feel unsatisfied with our handling of your data, or about any complaint that you have made to us about our handling of your data, you are
entitled to escalate your complaint to a supervisory authority. For the United Kingdom, this is the Information Commissioner’s Office (ICO), who is also our
lead supervisory authority. Its contact information can be found at https://ico.org.uk/global/contact-us/
