ECO BASE HQ LTD Privacy Notice

Privacy Notice Control.

This Privacy Notice is version 2.1 and is valid from 20 April 2021. It replaces and supersedes all other Privacy Notices associated with ECO BASE HQ LTD.

We take your privacy very seriously. This Privacy Notice details what Personal Data we collect and how we shall use it.

Please take time to read this Privacy Notice and ensure that you understand its contents.

Changes to this Policy

We continually review our Privacy Notice and update it where necessary. We advise that you regularly check our Privacy Notices for updates. We do not wish to bother you with lots of minor amendments, but where we make significant changes to our policy, we shall email you to inform you.

Our Name & Contact Details.

The Data Controller of your Personal Data is ECO BASE HQ LTD. This means the organisation decides how your personal data is processed and for what purposes. Our contact details are:

ECO BASE HQ LTD

2a Petre Court,
Petre Road,
Clayton-Le-Moors,
Accrington,
England,
BB5 5HY

Our telephone number is 01282 222590 & 0333 358 2120.

Personal data categories we collect.

We may collect, use, store and transfer different kinds of personal data about you which we have categorised as follows:

• Identity Data: This includes first name, maiden name, last name, marital status, title, date of birth and gender.
• Contact Data: This includes email address and telephone numbers.
• Financial Data: This includes Benefits and Income Information.
• Technical Data: This includes internet protocol (IP) address, 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 this website.
• Usage Data: This includes information about how you use our website, products, and services.
• Marketing and Communications Data: This includes your preferences in receiving marketing from us and your communication preferences.
• Aggregated Data: This includes statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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 privacy notice.
• Special Categories of Personal Data: This includes health and vulnerability related data that you may voluntarily share with us during the fulfilment of our services to you. We will always ask for your explicit consent to record and share Special Category Data.

For what purposes do we process personal data, and what are the lawful basis by which we process data?

ECO BASE HQ LTD processes your Personal Data for the following purposes:

• Supply, perform, manage, and fulfil our products and services to you which enable you to claim money that you are owed, will save you money or will strengthen your financial position and associated customer support and aftercare – Contract
• Make and manage customer payments – Contract
• Manage fees and charges due on customer payments -Contract
• Communicate with clients to fulfil, administer, or enforce contractual obligations via email, telephone, SMS text, postal mail, and push notifications – Contract
• Communicate with customers where we have your consent to do so via email, telephone, SMS text, postal mail, and push notifications – Consent
• Communicate with clients on matters where we have a legal obligation to do so via email, telephone, SMS text, postal mail, and push notifications – Legal Obligation
• Communicate with clients on matters where we have a legitimate interest to do so (see legitimate interest section below), via email, telephone, SMS text, postal mail, and push notifications -Legitimate Interest
• Direct market similar or aligned new products and services to our existing customers – Legitimate Interest, Consent
• Request specific consent to share customer personal data with specific fulfilment partners so that they may direct market similar or aligned new products and services to our existing customers – Legitimate Interest, Consent
• Verify the identity of individuals where necessary including for Subject Access Requests (SAR) – Contract
• Update clients about changes to how we process their personal data and/or new processing activities via email, telephone, SMS text, postal mail – Legal Obligation
• Gather feedback for service and product improvement via email, telephone, SMS text, postal mail – Legitimate Interest
• Share testimonials, case studies and feedback on our website and future marketing – Consent
• Resolve complaints and/or disputes – Legitimate Interest
• Request continuation of Consent prior to consent expiry – Consent
• Collect payments or arrears should we have the need to do so – Legitimate Interest
• Protect our organisation, staff, associates, suppliers, partners, and clients – Legitimate Interest
• Prevent, detect, and investigate fraud – Legal Obligation
• Prevent, detect, and investigate crime – Legal Obligation
• Comply with the law – Legal obligation
• Fulfil our statutory or regulatory obligations – Legal obligation
• Maintain our own accounts and records – Legal obligation
• For reporting, analytics, and product/service improvement (including training) – Legitimate Interest
• Improve and maintain data accuracy or completeness – Legitimate Interest
• Track your email engagement – Legitimate Interest
• Personalise your online experience – Legitimate Interest
• Conduct market research – Legitimate Interest
• To recruit and manage our staff – Contract, Legitimate Interest and Legal Obligation
• Sell your personal data – Legitimate Interest, Consent

Where we have used legitimate interest as the lawful basis for processing your Personal Data we may:

• Direct market products and services to you via post, emails, telephone, SMS text and push notifications where they are similar/aligned to us to our current products and services that enable you to claim money that you are owed, will save you money or will strengthen your financial position, and a soft opt-in exists.
• Request specific consent to share customer personal data with specific fulfilment partners so that they may direct market similar or aligned new products and services to our existing customers.
• For reporting, analytics, and product/service improvement (including training).
• Improve and maintain data accuracy or completeness.
• Track your email engagement.
• Personalise your online experience. This could include customising the content and/or layout of our pages for individual users, for both visitors and contributors.
• Conduct market research. Including research on the demographics, interests, and behaviour of our customers to help us gain a better understanding of different audiences and enable us to improve our service. This research may be conducted internally by our employees or we may ask another company to do this work for us. Data will be anonymised to protect your data rights for research purposes.
• Sell your personal data.
• Resolve complaints and/or disputes.
• To prevent, detect and investigate fraud.
• To prevent, detect and investigate crime.
• To fulfil our statutory or regulatory obligations.
• To maintain our own accounts and records, including recording any contact we have with you via post, emails, telephone, SMS text and push notifications.
• Sharing your personal data

ECO BASE HQ LTD may choose to share your personal data internally and/or share/sell your personal data externally to the business. Where we choose to share/sell your information, we shall do so for the following reasons:

• Where we have your “Consent” to do so. Where we process your data under the Consent Lawful Basis you have the right to withdraw consent. Please refer to “Your Right to Withdraw Consent” section below.
• Where necessary to fulfil the services and/or products we are “Contracted” to provide to you.
• Where we have a “Legal Obligation” and are required by law and to law enforcement agencies, judicial bodies, government entities, tax authorities or regulating bodies around the world, this includes communicating with you to update you about our privacy notice and changes to how we process your personal data.
• Where we have “Legitimate Interest” to do so, including.
• For the purposes listed in the “What are our legitimate interests for processing your data?” section above.
• For reporting, analytics, and service improvement purposes across our trading styles and/or within any future group construct should ECO BASE HQ LTD establish or become part of a group.
• Where one of our registered trading styles and/or current associated businesses provides a product or service similar/aligned with our organisation’s aim to help you and/or will strengthen your position that we do not currently provide ourselves. Presently these include:

ENERGYSMART GROUP NATIONWIDE LTD (97 Ribchester Road, Blackburn, England, BB1 9HT)

Where an external 3rd Party, with whom we are yet to have a relationship, provides a product or service that we do not currently provide ourselves, and which we believe would be of benefit to you and you would expect to receive and is similar/aligned to our business of Eco energy and/or helping you to:

• Claim money that you are owed.
• Save money, or.
• Strengthen your financial position

In this case we would contact you using Legitimate Interest to request specific Consent to share your Personal Data.

Where we believe it is necessary to protect or defend our rights, property or the personal safety of our people or visitors to our premises or websites.

• Where required for a proposed sale; reorganisation; transfer; financial arrangement; asset disposal; or any other transaction relating to our business and/or assets held by our business.
• We may outsource support functions of our business to trusted partners.

Where we choose and/or have your permission to share/sell your personal data with 3rd Party’s we will ensure that they have signed a contract that requires them to:

• Abide by the requirements of all relevant data protection and privacy legislation.
• Treat your information as carefully as we would
• Only use the information for the purposes it was supplied (and not for their own purposes or the purposes of any other organisation); and
• Allow us to conduct checks to ensure they are doing all these things.
• Selling your personal data

ECO BASE HQ LTD may choose to sell your personal data.

You have the Right to Object to us selling your personal data at any time and can do so by informing us by telephone, post, or email.

Where we choose to sell your information, we shall do so in the following circumstances:

• Where we have your “Consent” to do so.
• Where we have a “Legitimate Interest” to do so, including.
• Where required for a proposed sale; reorganisation; transfer; financial arrangement; asset disposal; or any other transaction relating to our business and/or assets held by our organisation.

For the purposes of generating revenue for our business we may sell your data to the categories of industry listed below:

• Financial Services
• Banking
• Breakdown and Recovery Services
• Insurance
• Claims Management Services
• Financial Products
• Funeral Plan
• Home & Contents Insurance
• Legal Services – Conveyancing, Wills, Trusts etc
• Life Insurance
• Mis-Sold Financial Products
• Mortgages
• Pre-paid Funeral Plans
• Private Medical Insurance
• Travel Insurance
• Mail Order

ECO BASE HQ LTD may transfer personal data to countries outside of the UK and/or EEA.

If data is transferred outside of the EEA, ECO BASE HQ LTD will put in place Standard Contractual Clauses with the Data Controller or Data Processor which contractually obliges them to protect your information to the same standard required by the General Data Protection Regulation and Data Protection Act 2018 post 31 December 2020.

Personal Data Retention Period

ECO BASE HQ LTD has the following data retention policies:

Where a Regulating Body directs a statutory retention period, we shall retain the relevant data for the statutory period. For example, your financial transactions data shall be retained for 7 years.

Where you have purchased, or enquired about purchasing, an ECO BASE HQ LTD product or services, we shall retain any personal details applicable to the contract delivery for a period of 7 years (name, email, telephone, postal address) after completion of the contract. During this time, we may contact you using consent and/or legitimate interest to market additional products or services.

Where you have downloaded free content from our site, we shall retain your contact details (name, email, mobile telephone number) for a period of 2 years, or until you exercise your Right to Object or opt out. During this time, we may contact you using legitimate interest to market similar free content that may be of interest to you.

Where you have signed up to receive information emails from ECO BASE HQ LTD, we shall retain your contact details (name, email, mobile telephone number, company, job title) for 2 years, or until you withdraw your consent.

Prospect contact details. Where you have enquired about one of our products or services that is designed to assist you to claim money that you are owed, enable you to save money; and/or will strengthen your financial position we shall retain your contact details for 7 years after the date of collection, or our last positive engagement, or until you withdraw your consent, whichever is latest, so that we may keep you informed if:

We expanded our portfolio of product or service offerings.

Where a new and/or additional PPI claim may be made that may come about due to current legal challenges, future legal challenges and/or fresh evidence of mis-selling or unfair commission.

New or emerging product or service offerings that may enable you to claim money that you are owed, will save you money or will strengthen your financial position are introduced.

Client contact details. Where you have completed part or all of our website webforms and/or we have provided you with a product or service that is designed for you to claim money that you are eligible to claim; and/or will enable you to save money; and/or will strengthen your financial position, we shall retain your contact details for direct marketing purposes for 7 years after any associated deadline (for example the PPI deadline) or full delivery of the product/service we have provided, so that we may keep you informed:

If we and/or any of our trading styles or group entities expand our portfolio of product or service offerings.

Where a new and/or additional claim may be made that may come about due to current legal challenges, future legal challenges and/or fresh evidence of mis-selling or unfair commission.

New or emerging product or service offerings that may enable you to claim money that you are owed, will save you money or will strengthen your financial position are introduced.

For our Tax claims service, we shall retain your contact details and relevant Tax claims data for 7 years, or the completion of your claim.

When we no longer need this information, we will anonymise your data and/or dispose of it securely.

The rights available to individuals in respect of the processing.

Unless subject to an exemption under legislation, you have the following rights with respect to your personal data:

Your right of access. You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information we process. You can read more about your Right to Access here. In most cases ECO BASE HQ LTD will not charge for this service however we do have the right to charge an administrative cost should we feel the request is excessive (excessive means that you submit a subject access request multiple times for the same or similar information). Fees will not exceed £50. Information will be provided within a month (30 days) from the day you request it. We will take all reasonable steps to confirm your identity before providing you with details of any personal information we may hold about you.

Your right to rectification. You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies.

Your right to erasure. You have the right to ask us to erase your personal information in certain circumstances.

Your right to the restriction of processing. You have the right to ask us to restrict the processing of your information in certain circumstances.

Your right to object to processing. You have the right to object to processing if we can process your information because the process forms part of our public task or is in our legitimate interests.

Your right to data portability. This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering a contract and the processing is automated.

Automated decision-making, including profiling. ECO BASE HQ LTD does not use currently use automated decision-making tools or profiling in the processing of your Personal Data.

If you wish to exercise any of your Individual Rights, you can do so by informing a member of our team or by writing to:

ECO BASE HQ LTD

Your Right to Withdraw Consent

You have the right to withdraw your consent to ECO BASE HQ LTD’s processing your data at any time. Please note that this only applies for personal data processed under the Consent Lawful Basis. To determine what of your personal data is processed under the Consent Lawful Basis, please refer to the “What are the lawful basis by which we process data?” section above.

If you decide you wish to withdraw your Consent from a processing activity that uses the lawful basis of Consent, you can do so by informing a member of our team or by writing to:

ECO BASE HQ LTD
2a Petre Court,
Petre Road,
Clayton-Le-Moors,
Accrington,
England,
BB5 5HY

Your Right to Lodge a Complaint with the ICO

You have the right to lodge a complaint with the UK’s Supervising Authority: The Information Commissioners Office. Prior to lodging a complaint, ECO BASE HQ LTD would like the opportunity to address any complaint you may have.

Should you have a complaint please in the first instance contact Us by emailing Complaint, or writing to: customerservice@ecobasehq.com

ECO BASE HQ LTD

2a Petre Court,
Petre Road,
Clayton-Le-Moors,
Accrington,
England,
BB5 5HY

If your complaint has not been resolved, you can lodge a complaint with the Information Commissioners Office via email https://ico.org.uk/global/contact-us/email/ or by writing to:

Information Commissioner’s Office

Wycliffe House
Water Lane
Wilmslow
Cheshire.
SK9 5AF.

Or by telephone on 0303 123 1113c