We know that providing personal information is an act of trust and we take that seriously.
We go into more detail later on this page, but here's the short and sweet version:
In a nutshell
Most of the data we collect and hold about you is for the purpose of providing your energy. We also use data to make Bulb's products and services better, and to help us advertise Bulb.
To supply you with energy
We gather information about you and your home so we can accurately supply your energy. For example, we need to know your address to supply the right property, and we need to know how much energy you use so we can send you accurate bills.
Where necessary, we share this with other organisations in the energy industry, like your old supplier, Ofgem and the organisations that maintain the national energy databases.
To make Bulb better
We collect data on how you use our website, App and other features. We track things like where you click on our site and what features you use. This lets us learn what's working well and what features we need to improve.
We sometimes share this data in an aggregated form with agencies or partners that are helping us. For example, we might tell a telecommunications partner how many phone calls we get a week.
To advertise Bulb
We use your data to help grow Bulb and spread renewable energy. If you're a member of Bulb, we share data with social media, search engine, and other advertising platforms so that we stop asking you to join Bulb, and instead show you content more relevant to you.
We also share aggregated data with agencies that help us with advertising. For example, we might share with an agency how many of our members live in Scotland.
To communicate with you
In addition to sending you key information about your account by email, from time to time we'll also send you information about things we think will interest you. This includes letting you know how much carbon you're saving each year by being with Bulb, updates on our referral programme, and reminding you about how you can manage your energy online.
Where necessary, we share your data with organisations that send communications on our behalf. For example, we ask Trustpilot to send invitations to our members to review Bulb.
Information that we collect
Information you provide us at sign-up
- Contact information: such as your name, address, email address, date of birth and telephone number.
- Vulnerability information: such as disabilities, age, or health conditions for you or a member of your household. This helps us provide suitable additional services.
- Financial information: such as your payment details and financial circumstances. We need your bank details if you want to pay by direct debit. If you have difficulty paying our bills, providing details of your circumstances helps us work with you to resolve this.
- If you are eligible for the Feed-in Tariff scheme: additional information to confirm your identity (such as a copy of your passport or driving licence, or proof of company registration) and information about your Feed-in Tariff installation (such as a certification document and your installation meter details). We are required to collect this information to comply with Ofgem's Feed-in Tariff scheme.
Information while we provide you services
- Information about your energy supply: such as your meter reference numbers and meter type. This ensures we link you with the right meter and keep industry databases accurate.
- Energy you use: such as details of your energy use and your supply start and end dates. If you have a smart meter or Bulb energy monitor we will take consumption data directly from your meter in line with the consents you have given us. We need details of your energy usage so we can send you accurate bills.
- Energy you generate: details of energy you generate under the Feed-In Tariff scheme. We need this information so we can accurately calculate the payments due to you.
- Smart meter information: if you have a smart meter it will transmit data that lets us know that it is safe and operating and recording correctly.
- Warm Home Discount and Affordable Warmth measures: If you apply for the Warm Home Discount or Affordable Warmth measures, you will be asked for information about any benefits you receive and money you get from employment, to assess your eligibility for assistance. We are required to collect this information to comply with Ofgem's Warm Home Discount scheme.
- Customer service data: when you get in touch by phone, email, chat or community posts we monitor, record and review those communications so we can provide the best possible service to you and all our members and so we can show evidence of transactions or events.
Information provided by others
Affiliates and partners: when you sign-up with Bulb through an affiliate or partner (such as a price comparison website), we are sent your personal information from that partner so we can enter into a contract with you.
Energy industry partners: metering and debt information can come from other organisations involved in supplying your energy, such as your old supplier and meter operators.
Landlords and estate agents: data such as your name and contact details may be provided to us by people moving in or out of a property you're occupying, or a landlord or estate agent. We may use this information to contact you in relation to the continuation of the energy supply to your property.
Councils, postal services, and data brokers: information such as contact details, homemoving status and other details about your circumstances can be provided by councils, postal services and data brokers. We will always check that these organisations have your consent or are otherwise legally permitted to share this information.
Referrers: data such as your name and contact details may be provided to us by people referring you to Bulb as part of our Referral Programme. We may use this information to contact you in relation to becoming a Bulb member.
How we use this information
It's important that you understand what we'll do with the data that we hold about you, as well as the lawful reasons we are allowed to do this.
We may sometimes combine information that we collect from you with information we obtain about you from third parties and affiliates and information derived from any other subscription, product, or service we may provide.
We use the information we hold about you for the following purposes:
Performing our contract with you
We need to process information in order to supply your energy and the services you've asked for under our contract. For example, we may use your information (such as your contact information) to organise your switch to Bulb, to take monthly payments and organise meter repair jobs.
Fulfilling our legal and regulatory obligations
Many of the ways we manage your energy are based on requirements set out in our Licence and by Ofgem directions and Codes, such as how we set out your annual statement and how we deal with disputes. We may also need to comply with court orders, and disclose information to law enforcement agencies where we are obliged to do so.
Adding you to our Priority Services Register with your consent
If you have let us know that you (or a member of your household) need extra care or have any vulnerabilities, we will ask for your explicit consent before we add your details to our Priority Service Register. This helps us take steps to ensure your safety.
Taking your smart meter readings with your consent
If you have a smart meter, we'll normally collect readings from your smart meter once a day. You can decide whether we take a reading for the entire 24-hour period or for each half-hour period. We won't take more than one reading a day unless you have given us your consent. If you'd prefer us to only take one reading a month, you can email us at firstname.lastname@example.org.
Analysing your smart meter readings to offer you new products and services with your consent
If you have a smart meter, we could use your smart meter readings to understand how you use your energy. For example, we could learn how to buy energy for lower prices and be able to build and offer you new products and services. We will only use your smart meter readings to do this if you have given us your consent. You can email us at email@example.com at any time to withdraw this consent.
For our legitimate business interests
This means that using your information is necessary for us to build our business and provide our services to you. We consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests. Our legitimate interests include:
- Maintaining and improving our services: for example, we may use your information that we obtain through your emails and calls to train our team. We may also use your information to ensure that our services are working as intended – for example, understanding which parts of the website are easiest to use. We may also contact you for suggestions on how we can improve the way we provide our services to you.
- Providing personalised services, including suggested payment amounts: for example, we may use information such as your account balance and expected annual energy use to make an automatic adjustment to your payment amount.
- Providing personalised advertising: we may let advertising platforms like Facebook and Google know that you are a member of Bulb by sharing your contact details with them. This means we can stop asking you to join Bulb once you're with us, and instead share information with you that we think you might be interested in.
- Communicating with you about our services: we may contact you about Bulb news, product updates and new products that we think you might be interested in. We may also contact you to provide you with offers, competitions, marketing materials and other promotional materials, both online and through other marketing channels, such as third party social networks, like Facebook.
- Measuring our performance and developing new services: for example, we use data for measurement to understand how our services are used. We also use aggregated data to understand our members and their energy usage better. This helps us develop offerings such as our Annual Impact Report.
- Helping to prevent and detect fraud or debt: we also need to be able to detect and prevent fraud and recover unpaid bills.
If you have questions about the lawful basis on which we collect and use your information, you can email our Data Protection Officer at firstname.lastname@example.org
Sharing your information
When we share your information
We sometimes need to allow our service providers to process personal information we hold about you on our behalf for the reasons set out in this Policy or as otherwise required by law.
We make sure that these third parties won't use your personal data for their own purposes and we only permit them to use it in accordance with our instructions and the law. This includes the following types of organisations:
- Energy industry partners: including other suppliers, network operators and energy market administrators.
- Payment providers: we work with payment providers to process your payments. We use GoCardless to process your direct debit payments, Stripe to process your debit card payments and Transferwise to process other payments to you (such as under the Feed-in Tariff). You can find more information on how these providers process your personal data and your data protection rights by looking at their privacy policies at the links above.
- Marketing agencies, search engines and social media networks: to advertise Bulb and to gather feedback on Bulb such as through customer surveys.
- People you have authorised us to share data with: such as family members, energy brokers, solicitors and debt management companies, so we can fulfil your requirements.
- Market regulators: such as Ofgem and consumer protection organisations such as the Energy Ombudsman, where we are obliged to do so under regulations.
- Price comparison sites and other affiliates: to ensure that we can fulfil a contract you have requested.
- Credit reference agencies (such as Experian): We may tell credit reference agencies how you're managing your account and whether you owe us money. These agencies can help us trace you if you have moved and we owe you money or you owe us money. More information is set out in Experian's Credit Reference Agency Information Notice.
- People you are referring to Bulb: if you refer a new member to us, we may share your first name and aggregated data about your energy use with the referred person.
When you share your own information
Sometimes you may share your information publicly, such as by posting on our Community page or on social media sites. Remember, when you share information publicly it may become accessible through search engines.
Sending your data outside the European Economic Area
Sometimes our agents and service providers are based outside the European Economic Area, so when working with them, we may pass your information outside of the European Economic Area to countries that do not have the same data protection standards as the UK.
You're in control
If we collect or handle your personal data, you have rights as an individual which you can exercise in relation to the information we hold about you:
- To correct or update your personal information, you can log into your Bulb Account.
- To delete your personal information, you can email us at email@example.com. We will delete any information that we no longer need to hold, but we won't always be required to do this. For example, we may need to hold your information to continue to provide your energy under our contract. If this is the case, we'll explain why.
- To ask us to restrict processing of your personal information or transfer your personal information to a different organisation, you can email us at firstname.lastname@example.org.
- To confirm if we are using your personal information or get access to all your personal information that we hold, in an easy to understand, portable and secure format, you can email us at email@example.com with the subject line "Subject Access Request".
- To object to the processing of your personal information, you can email us at firstname.lastname@example.org.
- To withdraw consent to process your data, you can email us at email@example.com at any time.
- To opt-out of marketing communications you can email us at firstname.lastname@example.org.
Once we receive a request from you, we will respond within at most 1 month, but usually a lot quicker. Before actioning these requests, we will need to positively identify you.
If you're unhappy with how we've handled or processed your personal information - or you want further information about your rights - you have the right to contact the Information Commissioner's' Office, the supervisory body that regulates handling of personal information in the UK.
Keeping your information secure
Whilst we cannot ensure or guarantee that unauthorised access to or unauthorised alteration, disclosure or loss of information will never occur, we work hard to prevent it. In particular:
- We use encryption to keep your data private while in transit.
- Your account information is protected for your privacy and security. Either this is through a password you have chosen or you can log-in to your account directly with your email address. Bulb and our agents will never ask for your password.
- To help keep your account and your personal information secure you should not disclose your password details to anyone. You should also make sure your Bulb account password is different from your email address password. We recommend you change your passwords from time to time.
- We review our practices for collecting, processing and storing personal information, including physical security measures, to guard against unauthorised access to systems and backups to prevent the loss of information. We will continue to enhance our security procedures as new technology becomes available.
- We restrict access to personal information wherever possible to people who need to know that information to process it and who are subject to contractual confidentiality requirements.
Retaining and holding your information
We keep the personal information we collect for no longer than is necessary for the purposes for which we collected it.
The length of time depends on the purposes for which we use it, or otherwise to meet our legal obligations.
We will delete any information as soon as we no longer have a valid reason to hold it. If this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
About this Policy
When this Policy applies:
For the purposes of this Policy, "we", "us", "our" and "Bulb" means Bulb Energy Ltd and other companies in the same group. Unless otherwise stated, Bulb is the Data Controller for your personal data.
This Policy applies to how we use your information in relation to our products and services generally.
This Policy doesn't apply to other companies' sites that you get to through our website or social media pages. So make sure you've read their policy before putting your personal information on their site.
Changes to this Policy:
We may change this Policy at any time. If we make any changes, we'll post them on this page. If they're substantive changes, we'll also have a more prominent notice letting you know. You can also email or write to us for a physical copy.
Last updated: The Policy was last updated on 11 July 2018.