Legal
Privacy policy
Online Direct Limited respects your privacy and is committed to protecting your personal data. This notice explains how we look after your personal data and tells you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
Important information and who we are
This privacy notice aims to give you information on how Online Direct Limited collects and processes your personal data, including any data you may provide through our website when you fill in any website forms and/or contact us via the website.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Online Direct Limited is the controller and responsible for your personal data (collectively referred to as “Company”, “Online Direct”, “we”, “us” or “our” in this privacy notice). We have appointed a data privacy team (DPT) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions, including any requests to exercise your legal rights, please contact the DPT using the details set out below.
Contact details
Full name of legal entity: ONLINE DIRECT LIMITED
Data privacy team: Data Privacy Team
Email address: dataprivacyteam@onlinedirect.co.uk
Postal address: 300 Pavilion Drive, Northampton, NN4 7YE
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
Your duty to inform us of changes — It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links — Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and
• Contact Data includes billing address, email address and telephone
• Financial Data includes bank account
• Technical Data includes internet protocol (IP) address, your login 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
• Profile Data includes your username and password, your interests, preferences, feedback and survey
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from
• Usage Data includes information about how you use our website, products and
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication
We also collect, use and share Aggregated Data such as 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. 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.
We do not collect any Special Categories of Personal Data about you (this includes details about your 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). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data — Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you, including through direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us. This includes personal data you provide when you:
• apply for our products or services;
• register on our website;
• create an account with us;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a survey; or
• give us some feedback.
Automated technologies or interactions — As you interact with our website, we may 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. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
Third parties or publicly available sources — We may receive personal data about you from various third parties, including data aggregators, energy suppliers and analytics providers; Contact, Financial and Transaction Data from providers of technical and payment services; and Identity and Contact Data from publicly available sources.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: where we need to perform the contract we are about to enter into or have entered into with you; where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data, other than in relation to sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Set out below is a description of the ways we plan to use your personal data, and the legal bases we rely on to do so. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
To register you — Data: Identity, Contact. Lawful basis: Performance of a contract with you.
To process and deliver payments and/or collect and recover money owed to us — Data: Identity, Contact, Financial, Transaction, Marketing and Communications. Lawful basis: (a) Performance of a contract with you; (b) Necessary for our legitimate interests (to recover debts due to us).
To manage our relationship with you, including notifying you about changes to our terms or privacy policy and asking you to leave a review or take a survey — Data: Identity, Contact, Profile, Marketing and Communications. Lawful basis: (a) Performance of a contract with you; (b) Necessary to comply with a legal obligation; (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
To enable you to partake in a survey — Data: Identity, Contact, Profile, Usage, Marketing and Communications. Lawful basis: (a) Performance of a contract with you; (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business).
To administer and protect our business and our website, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data — Data: Identity, Contact, Technical. Lawful basis: (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise); (b) Necessary to comply with a legal obligation.
To deliver relevant website content and advertisements to you, and to measure or understand the effectiveness of the advertising we serve to you — Data: Identity, Contact, Profile, Usage, Marketing and Communications, Technical. Lawful basis: Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences — Data: Technical, Usage. Lawful basis: Necessary for our legitimate interests (to define 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).
To make suggestions and recommendations to you about goods or services that may be of interest to you — Data: Identity, Contact, Technical, Usage, Profile. Lawful basis: Necessary for our legitimate interests (to develop our products/services and grow our business).
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us — We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. You will receive marketing communications from us if you have requested information from us and, in each case, you have not opted out of receiving that marketing.
Third-party marketing — We will get your express opt-in consent before we share your personal data with any company outside the Online Direct group of companies for marketing purposes.
Opting out — You can ask us or third parties to stop sending you marketing messages at any time by contacting us. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service experience or other transactions.
Cookies — You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.
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 explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above: Internal Third Parties (as set out in the Glossary); External Third Parties (as set out in the Glossary); and third parties to whom we may choose to sell, transfer or merge parts of our business or our assets, or which we may acquire or merge with. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
International transfers
We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called “binding corporate rules”.
Whenever we transfer your personal data out of 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 by the European Commission; or, where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield, which requires them to provide similar protection to personal data shared between Europe and the US.
Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymise your personal data for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Withdraw consent at any time.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required — You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
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.
Time limit to respond — We try to respond to all legitimate requests within one month. Occasionally it may 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.
Glossary
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Internal Third Parties means other companies in the Online Direct group. External Third Parties means service providers that provide IT and system administration; professional advisers including lawyers, bankers, auditors and insurers; HM Revenue & Customs, regulators and other authorities; and energy suppliers and service providers.