Privacy Notice

1. Important notice

This is the Privacy Notice of ORIGAMI ENERGY LIMITED (company number 08619644) and its wholly-owned subsidiaries Origami Storage Limited (company number 10436515) and OSSPV001 Limited (company number 10933403), each of whose registered office is at Ashcombe Court, Woolsack Way, Godalming GU7 1LQ (“Origami”, “we”, “us” or “our”) and sets out how we collect and process your personal data. This Privacy Notice also provides certain information that is legally required and lists your rights in relation to your personal data.

This Privacy Notice relates to personal information that identifies “you” meaning our customers and potential customers, our suppliers, consultants, advisers and other individuals outside our organisation who browse our website or with whom we otherwise interact.

We refer to this information throughout this Privacy Notice as “personal data” and paragraph 3 sets out further detail of what this includes. Please read this Privacy Notice to understand how we may use your personal data.

If you are an employee, contractor or otherwise engaged in work for us or applying to work for us, a separate privacy notice applies to you instead. This Privacy Notice is not intended for children and we do not knowingly collect personal data relating to children.

This Privacy Notice may vary from time to time so please check it regularly. Where we are required to give you direct notice of any variation, we will do so.  This version of our Privacy Notice was published in May 2018 and is the most recent version.

2. How to contact us

Data controller and contact details

For the purposes of relevant data protection legislation, each of the aforementioned Origami companies may be controllers of your personal data and as a controller each Origami company uses the personal data it holds about you in accordance with this Privacy Notice.

If you wish to correct your personal data held by Origami or to opt out at any time from receiving marketing correspondence from any Origami company or to alter your marketing preferences please contact info@origamienergy.com.

If you need to contact Origami in connection with our use or processing of your personal data, or to gain access to it then Origami’s contact details are: Origami, Tintagel House, 92 Albert Embankment, London SE1 7TY; info@origamienergy.com; T: 03307260050.

Data Privacy Manager

The Data Privacy Manager (DPM) for each of the aforementioned Origami companies is Gunther Puffer.  The DPM can be contacted in accordance with paragraph 2 above.

3. Categories of Personal Data We Collect

3.1
The categories of personal data about you that Origami may collect, use, store, share and transfer are:

  • Individual Data. This includes personal data which relates to your identity, such as your first name, middle name, last name, username or similar identifier and your contact details such as your email address and telephone numbers;
  • Account and Profile Data. This includes personal data which relates to your account or profile on our website, such as your username and password, interests, preferences, feedback and survey responses;
  • Advertising Data. This includes personal data which relates to your advertising preferences, such as information about your preferences in receiving marketing materials from us and your communication preferences as well as your personal interests;
  • Information Technology Data. This includes personal data which relates to your use of our website, such as your internet protocol (IP) address, login data, traffic data, weblogs and other communication 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 our website;
  • Economic and Financial Data. This includes personal data which relates to your finances, such as your bank account and information which we collect from you for the purposes of the prevention of fraud;
  • Sales Data. This includes personal data which relates to the transactions you have conducted with us, such as details about payments to and from you;
  • Audio and Visual Data. This includes personal data which is gathered using our recording systems in the form of images, video footage and sound recordings that is taken at any of our locations or otherwise by us for promotional purposes;
  • Health Data. This includes personal data which is gathered for health and safety purposes including any accident report or claim;
  • Market Research Data. This includes personal data which is gathered for the purposes of market research.

We may also create Personal Data about you, for example, if you contact us by telephone to make a complaint about any aspect of our business, then we may make a written record of key details of the conversation so that we can take steps to address the complaint.

3.2
We also obtain and use certain aggregated data such as statistical or demographic data (“Aggregated Data”). Aggregated Data may be derived from your personal data but does not directly or indirectly reveal your identity. For example, we may aggregate your Information Technology Data to calculate the percentage of users accessing a specific feature on our website. However, if we re-combine or re-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 Privacy Notice.

3.3
Save in very limited circumstances (such as the Health Data referenced at 3.1 above), we do not collect special category data.

4. The sources from which we obtain your personal data

4.1
We obtain your personal data from the following sources:

4.1.1
Directly from you, either in person (at our locations or otherwise), via our website, apps or by telephone or via hand held PDAs (for example bar code scanners at marketing events). This could include personal data which you provide when you:
(a) place an order for our products or services on behalf of your organisation;
(b) subscribe to our marketing communications;
(c) request information on our products or services or for other marketing to be sent to you; or
(d) complete a form or survey from us or give us feedback.

4.1.2
Automated technologies, such as cookies, server logs and other similar technologies. We may automatically collect Information Technology Data about your equipment, browsing actions and patterns by using cookies, server logs and other similar technologies. We may also receive Information Technology Data about you if you visit other websites or apps employing our cookies. Please see our cookie policy for further details.

4.1.3
Third parties, such as:
(a) analytics providers (such as Google Analytics or Leadfeeder);
(b) subcontractors who provide technical or other services;
(c) providers of social media platforms (such as Facebook, Twitter and Linkedin) for example where you share our content through social media, for example by liking our Linkedin post, following or tweeting about us on Twitter.

4.1.4
Publicly available sources, such as:
(a) Companies House;
(b) HM Land Registry;
(c) your company website; and
(d) your Linkedin profile.

5. How we use your personal data and our basis for using it

5.1
Where we are relying on a basis other than consent we may rely on one or more of the following legal bases when processing your personal data. We have set out below the purposes for which we may process your personal data and the basis on which we can do this (this is what the law allows):

(a) To register you as a new customer and process your order.

Categories of personal data are Individual data, Economic and Financial data, Account and Profile data

We do this on the basis that the processing is necessary
· to progress and/or perform a contract with you;
· in some circumstances, to enable us to comply with the law; and
· for our legitimate interest in the provision of goods and services to our customers.

(b) In order to perform our contractual obligations to you. This would include:

· processing and performing any agreed services;
· giving instructions to our subcontractors, professional advisers, insurer or other parties to the extent relevant to the performance of our contract with you;
· orders placed by us where you are a supplier;
· making or receiving payments, fees and charges; and
· collecting and recovering money owed.

Categories of personal data are Individual data; Economic and Financial data; Account and Profile data; Sales Data

We do this on the basis that the processing is necessary
· to perform any contract entered into with you; and
· for our legitimate interests in enforcing any contract including to recover debts owed to us.

(c) In order to comply with our own legal obligations, e.g. health and safety legislation, or to assist in an investigation (e.g. from the police).

Categories of personal data are Individual Data; Audio and Visual Data; Health Data.

We do this on the basis that the processing is necessary
· for us to comply with the law; and
· in order to protect the vital interests of an individual.

(d) In order to use your personal data in life or death situations and there is no time to gain your consent (e.g. in the event of an accident or illness or injury or some other related emergency or to record any accident or injury or other incident you may suffer when visiting any of our locations or we have to give your personal details to medical personnel)

Categories of personal data are Individual Data; Health Data.

We do this on the basis that the processing is necessary
· for us to comply with the law; and
· in order to protect the vital interests of an individual;
· defence and legal proceedings
· in connection with our legitimate interests including in connection with procuring and maintaining insurance cover.

(e) In order to manage our relationship with you including:

· to send you important notices such as communications about changes to our terms and conditions and policies (including this Privacy Notice);
· to provide you with important real-time information about products or services you have ordered from us (e.g. a change of time or location due to unforeseen circumstances); and
· to send you information you have requested;
· to deal with your enquiries; and
· to ask you to leave a review or feedback on us.

Categories of personal data are Individual Data; Account and Profile Data; Sales Data; Advertising and Marketing Data.

We do this on the basis that the processing is necessary
· to perform any contract entered into with you;
· to comply with the law; and
· for our legitimate interests in the management and operation of our business, to keep our records updated and to study how customers use our products/services.

(f) In order to administer and protect our business, deal with any misuse of our website and to comply with our security policies at our locations.

Categories of personal data are Individual Data; Account and Profile Data; Information and Technology Data; and Economic Data

We do this on the basis that the processing is necessary
· for our legitimate interest in provision of administration of our business and IT services, network security, to prevent fraud; and necessary to comply with the law.

(g) In order to make suggestions and recommendations to you about goods or services that may be of interest to you, deliver relevant website content and advertisements to you and to measure or understand the effectiveness of our advertising.

Categories of personal data are Individual Data; Sales Data; Information and Technology Data; and Advertising and Marketing Data

We do this on the basis that the processing is necessary
·  for our legitimate interests to study how customers use our products/services, to grow our business by generating interest in our product and services with business contacts within relevant industries, to develop our products and services and ensure our marketing is relevant to you, and to inform our marketing strategy; or
· we have obtained your consent.

(h) For internal purposes to use data analytics, to identify usage trends, determine and measure the effectiveness of promotional campaigns and advertising and to improve our website, products/services, marketing, customer relationships and experiences.

Categories of personal data are Individual Data; Information and Technology Data; Advertising and Marketing Data; Market Research Data

We do this on the basis that the processing is necessary
·  for our legitimate interests in defining types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy.

(i) To communicate with you about, and administer your participation in, special events or webinars.

Categories of personal data are Individual Data; Account and Profile Data; Sales Data; Information and Technology Data; Advertising and Marketing Data; 

We do this on the basis that the processing is necessary
· for performance of a contract with you; and
· for our legitimate interests to promote our business

(j) To sell, make ready for sale or dispose of our business, in whole or in part including to any potential buyer or their advisers, or in relation to any refinancing. 

Categories of personal data are Individual Data; Account and Profile Data; Sales Data; Information and Technology Data; Advertising and Marketing Data; Economic and Financial Data;

We do this on the basis that the processing is necessary 
· for our legitimate interests in the sale or disposal of our business or assets and in the context of a business reorganisation or group restructuring exercise.

(k) In order to enforce or apply our terms of use, terms and conditions of supply and other agreements with third parties.

Categories of personal data are Individual Data; Account and Profile Data; Sales Data; Economic and Financial Data;

We do this on the basis that the processing is necessary
· for our legitimate interests in protecting our business and property and recovering debts owed to us.

5.2
Where we may rely on consent

5.2.1
We would like to use your personal data for a variety of different purposes. For certain of these purposes it is appropriate for us to obtain your prior consent. The legal basis of consent is only used by us in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way. Where we rely on consent, you may at any time withdraw the specific consent you give to our processing your personal data by following the opt-out links on any marketing message sent to you or by contacting us at any time (using the contact details set out in paragraph 2).

5.2.2
Please note even if you withdraw consent for us to use your personal data for a particular purpose we may continue to rely on other bases to process your personal data for other purposes.

6. Who receives your personal data

We may disclose your personal data to:

  • third party data processors who may process data on our behalf to enable us to carry out our usual business practices. Any such disclosure will only be so that we can process your personal data for the purposes set out in this Privacy Notice;
  • our PR agency and customer feedback providers;
  • HMRC, legal and other regulators or authorities, including those who request your personal data or to report any potential or actual breach of applicable law or regulation;
  • external professional advisers such as accountants, bankers, insurers, auditors and lawyers;
  • law enforcement agencies, courts or other relevant party, to the extent necessary for the establishment, exercise or defence of legal rights;
  • third parties where necessary for the purposes of prevention, investigation, detection or prosecution of criminal offences, fraud protection or the execution of criminal penalties;
  • third parties which are considering or have decided to acquire some or all of our assets or shares, merge with us or to whom we may transfer our business (including in the event of a reorganisation, dissolution or liquidation);
  • suppliers and subcontractors in connection with the performance of any contract or proposed contract; and
  • our shareholders and directors.

7. Personal data about other people which you provide to us

7.1
If you provide personal data to us about someone else (such as one of your directors or employees, or someone with whom you have business dealings) you must ensure that you are entitled to disclose that personal data to us and that, without our taking any further steps, we may collect, use and disclose that personal data as described in this Privacy Notice.

7.2
You must ensure the individual concerned is aware of the various matters detailed in this Privacy Notice, as those matters relate to that individual, including our identity, how to contact us, the way in which we collect and use personal data and our personal data disclosure practices, that individual’s right to obtain access to the personal data and make complaints about the handling of the personal data, and the consequences if the personal data is not provided.

8. Accuracy of your personal information

It is important that the personal data we hold about you is accurate and current and we take all reasonable precautions to ensure that this is the case but we do not undertake to check or verify the accuracy of personal data provided by you. Please keep us informed if your personal data changes during your relationship with us. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.

9. International Transfers of Personal Data

It is possible that personal data we collect from you may be transferred, stored and/or processed outside the European Economic Area.  In connection with such transfers we will ensure that:

(a) there are appropriate safeguards in place pursuant to Article 46 (or English law equivalent) of GDPR such as binding corporate rules or the model approved contractual clauses between us and the recipient – details of safeguards can be obtained by contacting us using the contact details set out in paragraph 2; or

(b) the transfer is one approved by the European Commission as providing adequate protection envisaged by Article 45 GDPR (or English law equivalent) such as to a country approved by the European Commission or privacy shield; or

(c) one of the derogations for specific situations in Article 49 GDPR (or English law equivalent) applies to the transfer including explicit consent or necessary for the performance of a contract or exercise or defence of legal claims.

10. How long we will store your personal data for

The period for which we will store your personal data will depend on the reason we have that data.  Where we hold your personal data:

(a) in connection with a contract, we will store that data for the duration of the contract, the relevant limitation period for that contract and one more year;

(b) to comply with our legal obligations, we will store that data for so long as it is necessary for us to hold that data;

(c) for purposes to which you have consented, in accordance with your consent;

(d) for our business’s legitimate interests, we will store that data for so long as we have a lawful basis to do so.  We will review data held on this basis at least annually and will continue to store it only where we determine that we continue to have a lawful basis to do so.

11. Contractual or statutory requirements on you to provide personal data

In certain circumstances the provision of personal data by you is a requirement to comply with the law or a contract, or necessary to enter into a contract.

It is your choice as to whether you provide us with your personal data necessary to enter into a contract or as part of a contractual requirement. If you do not provide your personal data then the consequences of failing to provide your personal data are that we may not be able to perform to the level you expect under our contract with you or we may not be able to contract or perform at all.

12. Automated decision making

We do not currently use automated decision-making tools in our processing of your personal data.

13. Your rights in relation to your personal data

Subject to applicable law including relevant data protection laws, in addition to your ability to withdraw any consent you have given to our processing your personal data (see paragraph 5.2), you may have a number of rights in connection with the processing of your personal data, including:

  • the right to request access to your personal data that we process or control;
  • the right to request rectification of any inaccuracies in your personal data or, taking into account the purposes of our processing, to request that incomplete data is completed;
  • the right to request, on legitimate grounds as specified in law:
  • erasure of your personal data that we process or control; or
  • restriction of processing of your personal data that we process or control;
  • the right to object, on legitimate grounds as specified in law, to the processing of your personal data;
  • the right to receive your personal data in a structured, commonly used and machine-readable format and to have your personal data transferred to another controller, to the extent applicable in law; and
  • the right to lodge complaints regarding the processing of your personal data with the Information Commissioner’s Office or other relevant supervisory body. Please see https://ico.org.uk/concerns/ for how to do this.

If you would like to exercise any of the rights set out above, please contact us using the contact details set out in paragraph 2.

14. Links to other websites

This policy only applies to Origami Energy Limited and its wholly-owned subsidiaries. If you link to another website from our website, you should remember to read and understand that website’s privacy policy as well. We do not control unconnected third-party websites and are not responsible for any use of your personal data that is made by unconnected third party websites.

Give us a call on 0330 726 0050 to speak to one of our experts. Alternatively you can send us a message and we’ll get back to you.