Hugo Technologies Limited, a company registered in England and Wales with company number 10551450 and its registered office at 117a Blackbrook Lane, Bromley, England, BR1 2LP (Hugo, we or us) is committed to protecting and respecting your privacy.
For the purpose of the EU GDPR, the version of the General Data Protection Regulation as implemented by the United Kingdom (UK GDPR) and the Data Protection Act 2018 (Act), we act as a controller in relation to your personal data.
Information we may hold about you
We may collect and process the following data about you:
- Information you give to us. You may give us information about you by filling in forms on our service, or by corresponding with us by phone, email or otherwise. This includes information you provide when you register to use our service, participate in discussion boards or other social media functions on our service, or when you contribute to our energy top tips.
- You or other users may provide us with information about you when you or they share a referral code with you.
- The information you give us may include your name, address, email address and phone number, financial and credit card information, personal description, photograph, smart energy meter data; energy provider data and any other information you provide.
With regard to each of your visits to our service, we may automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer or mobile phone to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- location data to determine your current location; some of our location-enabled services require your personal data for the feature to work;
- information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our service (including date and time); pages within our service you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number;
- information in relation to your energy usage through your smart meter;
We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on our service.
We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them. For example, some price comparison websites may hold information about you, which they amalgamate with information that we hold about you in order to optimise our service. We also obtain your SmartMeter data from third party suppliers (provided you have asked us to do so).
Google Analytics or other software will be used in order to help us understand how our users interact with our service. The information gathered from this service is anonymous, but will ultimately help us shape a better user experience for our customers.
How do 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 where it is necessary in order for us to perform our contract with you, or necessary for our legitimate interests (or those of a third party), and your interests, rights and freedoms do not override those interests, or where we need to comply with a legal or regulatory obligation.
We will use your personal data in the following ways, on the legal bases that it is necessary for us to perform our contract with you and for our legitimate interests (or those of a third party), and that your interests, rights and freedoms do not override those interests:
- we will provide you with access to our service (including creating energy usage projections and reports, displaying energy price comparisons and prices, providing you with notifications as to your energy usage and other updates relating to your energy) and the ability to register as a new service user, including granting you access, allowing you to access all of the services we agree to provide to you;
- as part of our service, we will provide you with a monthly email report on your estimated energy usage, expenditure and other key information;
- we will carry out any other obligations arising from the contract entered into between us and you, including processing payments, fees and any charges, and providing you with customer support;
- to enable you to participate in a prize draw, competition or complete a survey;
- we will use your smart energy meter data to regularly update the page which shows data usage on our service and to provide a comparison of energy providers’ rates specifically tailored to your requirements.
- we will administer and protect our business and our service including troubleshooting, data analysis and system testing;
- we may send you direct marketing communications in relation to similar products or services that we think may be of interest to you (provided that you have an absolute right to opt-out of any of these communications at any time, including at the time of providing us your personal data or at any time thereafter); and
- we will use your personal data to regularly update and rectify any personal data we hold in relation to you and to notify you of any changes to our service or any other services.
Generally, we do not rely on consent as a legal basis for processing your personal data, provided that we will get your consent before sending any third party direct marketing communications to you via email or text message. You have the right to withdraw consent at any time by contacting us.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Disclosure of Your Information
We may share your personal information with any member of our company, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may share your information with selected external third parties, including:
- marketing providers, hosting providers, and other third party providers that we use for the purposes of carrying out our obligations and exercising our rights;
- price comparison sites and white label software providers that we use to provide our energy price comparison service to you;
- third parties who provide us with your SmartMeter data (provided you have asked us to obtain such SmartMeter data from them), in particular we may need to provide them with sufficient information to allow them to verify your identity and the fact that we are authorised to access your SmartMeter data;
- Carbon off-setting providers. We will only do this as necessary in order to offset your carbon use where requested by you, and the information we share will be limited to the information necessary for us perform our functions in offsetting your carbon use;
- third parties where you ask us to send your referral code to them;
- price comparison websites when you ask us to direct you to those websites.
In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If Hugo or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our end user agreement and other agreements, or to protect the rights, property, or safety of Hugo, our customers, or others.
Third Party Links
Our service may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.
Where We Store Your Personal Data
The data that we collect from you may be transferred to, and stored at, a destination outside the UK or the European Economic Area (EEA). It may also be processed by staff operating outside the UK or the EEA, who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your booking, the delivery of a course, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.
If you are a UK citizen based in the UK or an EU citizen based in the EEA, then whenever we transfer your personal data out of the UK or the EEA (other than from the UK to the EEA), we will only transfer your personal data:
- to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
- if an appropriate safeguard has been put in place; or
- if one of the exceptions under Article 49 of the GDPR applies.
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 particular:
- we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know;
- all personal data is stored on secure servers;
- payment transactions will be encrypted using SSL technology; and
- we comply with any third party protocols relating to the supply and sharing of energy usage and SmartMeter data.
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. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our service, and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our service, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing at any time by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at firstname.lastname@example.org.
You have various statutory rights in relation to your personal data. In particular, you have the right to:
- object to direct marketing communications at any time;
- request and obtain access to your personal data;
- rectification or erasure of your personal data, in certain circumstances;
- object to or restrict the processing of your personal data in certain circumstances;
- have your personal data stored in a manner in which it is portable from the environment in which it is stored by us to another environment; and
- file a complaint with the Information Commissioner’s Office.
We reserve the right to request that you provide evidence of your identification if you ask us to carry out any steps in relation to your personal data.
Energy comparison and switching service
Our gas & electricity comparison service is provided by Decision Technologies Limited (“Decision Tech”), Company Reg No: 05341159. Registered address: First Floor, High Holborn House 52-54 High Holborn London WC1V 6RL. Decision Tech is an appointed representative of Moneysupermarket.com Financial Group Limited, which is authorised and regulated by the Financial Conduct Authority (FCA FRN 303190).
Decision Tech is an independent controller of your personal data, and we are not liable for any acts taken by Decision Tech in its capacity as controller of your personal data.
When you use the comparison service, we share your personal data with Decision Tech to find out what energy tariffs are available to you. It will share limited details about you with its suppliers, for example Decision Tech share your address with GB Group plc, who provide Decision Tech’s address look-up service.
If you choose to switch energy suppliers, the energy supplier you are switching to will provide you with the terms and conditions for your new energy tariff. The basis on which the energy supplier to which you are switching uses your personal data will be set out in their privacy notice, which we advise you to read.
A cookie is a small information file that is sent to your computer, mobile or other device when you visit a website and it will recognise your device on future visits. These types of files do a number of different jobs, such as remembering your preferences and chosen items, improving your service experience and ensuring that the adverts or offers you see online are more relevant to you.
You may delete or block these cookies, but if you do, then these features will stop working, and some of our online services may not work as intended.
The cookie-related information is not used to identify you personally, and the pattern data is fully under our control (except in the case of the anonymous analytics). These cookies are used only for the purposes as described here.
- to ensure that content from our service is presented in the most effective manner for you and for your computer.
- to administer our service and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our service to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our service safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and
- to make suggestions and recommendations to you and other users of our service about goods or services that may interest you or them.