We are committed to protecting your privacy and to complying with applicable data protection and privacy laws. This privacy notice (together with our terms of service) tells you how we collect, use and protect your information when you visit our website or use our energy management services (“services”), and your rights to your information. We will only use information we collect about you in accordance with this privacy notice.
This notice is effective from 15th October 2019 and may be updated from time to time.
Who we are
By “we”, “us”, “our” or “Levelise” we mean Levelise Limited, a company registered in England No. 10653159 at Edmund Halley Road, Oxford Science Park, Oxford OX4 4GB, UK.
Levelise the assigned data controlled for the USER Project; this means that we decide how your personal data is processed and for what purposes.
Your personal data
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. Personal data does not include anonymous data, i.e. data where the identity has been removed. The processing of personal data is governed by the General Data Protection Regulation 2016/679 (the “GDPR”).
What data we collect and how
If you sign up to participate in the trial, we may collect personal information that includes:
- Locational data: Your postcode – for our services we use the approximate location of your home based on a postcode sector that identifies your home only as one of more than 2500 properties. Your postcode sector is your postcode excluding the final two alphabetic characters, for example, for the postcode BS3 2AA the postcode sector is BS3 2.
- Energy usage data: Energy use in your home, including when and how much energy is consumed by your household appliances, or produced by your solar installation, or other microgeneration equipment. Your electricity supplier, tariff information, and distribution network operator (DNO). Your solar feed-in tariff.
- Technical data: The specification of your solar and battery installation (e.g. manufacturer, model, size etc). Monitoring information about the state of your battery, including charge level, temperature, voltage, state of heath, charge/discharge power. IP address, browser type and version, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our web site.
- Auditing data: Use of some website or app functions are logged to identify and isolate usage patterns and system problems (e.g. successful logins are logged, but the log only uses a user id number and does not store details of passwords used to login).
- Personal details: Your username and email address.
- Email Correspondence: Any emails you have sent us, any emails we have sent you, and any emails we have received from parties dealing directly with you, referencing you or your data.
Emails will be stored separately from the data store for the service we are providing you. A link between personal information from email correspondence will not be stored in our data store. When your data is collected we store it in pseudonymised form. By that we mean that when stored, your data is referenced using only a unique identification number. We do not store personally identifiable information such as your name, address or telephone number. Your email address will only be stored in pseudonymised form, so no-one accessing our data store will be able to directly read your email address.
We typically collect information in three ways:
- If and when you provide information to us (e.g. through use of our website or product registration).
- Through a device installed in your home which is connected to one of our services. This device will monitor and manage electrical equipment in your home (e.g. with your solar and battery installation, heat pump or other energy consuming/producing appliances).
- From outside sources (e.g. weather data feeds), or third parties (e.g. your energy supplier or renewable energy installer).
How we protect your information
The security of your information matters to us. In order to protect your information, we have put in place physical, electronic and procedural safeguards. For example, these include:
- Storing your data in a highly secure cloud environment hosted by Amazon, IBM, Microsoft and Google.
- Ensuring that data sent between you and Levelise is secured using industry-standard TLS (Transport Layer Security) encryption.
- Restricting access to relevant personnel at a single location.
What we do with your data
We will only use personal information where we are allowed to by law. This will be under one or more of the following circumstances:
- To perform our contract we have or will have with you, either directly or via a third party.
- To operate our web site and to deliver the services that you have requested.
- It is necessary for us to run our business and to give you the best possible service.
- To comply with a legal or regulatory obligation.
- We will always contact you in the way you have asked us to contact you.
For further detail on how we use your personal information please refer to this table:
Type of data
Deliver and monitor the services specified in our contract with you.
With your informed consent if you have agreed to participate in a trial of new or future services.
Use data analytics to improve our website.
Necessary for us to run our business: to keep our website updated and relevant.
Correspond with you via email to satisfy any questions you have about your data or the service we provide.
With your informed consent if you initiated the email correspondence. Performance of our contract with you either directly or via a third party.
Automated decision making
Our services are designed to optimally manage and enhance the performance of your battery system and other home appliances within a community. We do this by using your historical energy usage data and other inputs (like weather or calendar data) to forecast your future energy needs. Based on these forecasts, and others in the community, our automated decision making considers factors such as fairness (ensuring we do not over or under benefit you through the use of your battery), the reliability and security of the services we provide to you and others, the cost-benefit of using your battery vs others in the community, and other technical constraints before deciding how best to manage your battery.
Transferring your information overseas
Your personal information may be transferred and stored in countries outside the European Economic Area (EEA), including some that do not have laws that provide the same level of protection for personal information. When we do this, we will ensure it has an appropriate level of protection.
How long we keep your information
We will only retain your personal information for as long as necessary for the reason we have collected it, including for any contractual, legal or regulatory requirements we have to comply with. Generally, for the services we provide, this means that we will have to store the information for at least 12 months.
In some circumstances we may retain your data for longer than 12 months. When determining how long to retain your personal data, we consider amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorised use or disclosure of your personal information; the purposes for which we process your personal information and whether we can achieve those purposes through other means; and any applicable legal and regulatory requirements.
In some circumstances we may anonymise your personal information, so that it can no longer be associated with you, and use this indefinitely without further notice.
Email correspondence will be retained for at least 5 years.
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data information:
- The right to request a copy of your personal data.
- The right to request that we correct any personal data if it is found to be inaccurate or out of date.
- The right to request your personal data is erased where it is no longer necessary for us to retain such data.
- The right to withdraw your consent to the processing at any time, if consent is relied upon as a processing condition.
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller (known as the right to data portability).
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing.
- The right to object to or restrict the processing of personal data in certain circumstances.
- The right to lodge a complaint with the Information Commissioners Office.
To exercise your rights in relation to your personal information, please email: email@example.com
You are able to exercise your rights free of charge, but if you make unfounded, repetitive or excessive requests, we may charge you to carry these out or refuse to act on such requests.
We will try to respond to all requests within one month. If your request is complex or if you make lots of requests, we may extend our time to respond. If this is the case, we will let you know.
If you wish to raise a complaint on how we have handled your personal data, you can contact us to have the matter investigated. If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law, you can complain to the Information Commissioner’s Office at: https://ico.org.uk
When you login to our website a cookie will be stored in your browser. This is used to continually authenticate who you are, including if you close your browser view and return at a later point. Settings you choose within our website may also be stored within your browser.
How we monitor web traffic
When you visit our website we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. Click here if you would like to know more about Google Analytics.
To exercise all relevant rights, for queries or if you have concerns or complaints please contact us in the first instance at firstname.lastname@example.org