Privacy Policy

October 2023


Privacy Policy


Who are we?

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 (Hugowe or us) is committed to protecting and respecting your privacy.



What does this policy cover?



This policy (together with our website terms of use, user agreement and any other documents referred to in them) :

  • sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
  • explains how and why we collect and use your personal data;
  • explains how long we keep your personal data for;
  • explains when, why and with who we will share your personal data;
  • explains the effect of refusing to provide the personal data requested;
  • explains where we store your personal data and whether we transfer your data outside of the UK;
  • explains the different rights and choices you have when it comes to your personal data; and
  • explains how you can contact us.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.  By signing up to use our app, website or service (our service) you are accepting and consenting to the practices described in this policy.

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:


Registration Information: .   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.  It may include your name, address, email address and phone number, user name, personal description, photograph, smart energy meter data; property information, energy provider data and any other information you provide.



Marketing Preferences: You may give us information about you by filling in forms on our service, completing questionnaires about your property, or by corresponding with us by phone, email or otherwise.  This includes your preferences in receiving marketing from us and any third parties connected with us. You or other users may provide us with information about you when you or they share a referral code with you Identity Data. It may include your name, address, email address and phone number, user name, property description or similar identifier.


Financial Data.  Financial and credit card information,


Transaction Data: Includes details about any transactions made by you.

With regard to each of your visits to our service, we may automatically collect the following information:


Technical Information, which includes the following:

  •  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.



How Is Your Personal Data Collected?

We will collect and process the following data about you:


Information you give us. This is information (including Registration, Identity, Financial, and Marketing and Communications Data) you consent to give us about you by registering, filling in forms, by corresponding with us (for example, by email or chat). And completing questionnaires about your property. If you contact us, we will keep a record of that correspondence.


Information we receive from other sources including third parties and publicly available sources. 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).


Device Data. 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.

n3rgy data service

With your consent, we use n3rgy data service ( to interface with the national smart meter systems in order to collect, store, manage and share with us your Smart Meter data. This service uses the Smart Energy Code  (  Party credentials and Party ID of its parent, N3RGY LIMITED, incorporated and registered in England and Wales with the company number 11203504 whose registered office is at 4 Ovington Drive, Fleet, United Kingdom, GU51 1DF.

This service uses the Smart Energy Code  (  Party credentials and Party ID of its parent, N3RGY LIMITED, incorporated and registered in England and Wales with the company number 11203504 whose registered office is at 4 Ovington Drive, Fleet, United Kingdom, GU51 1DF.

You can withdraw consent at anytime by contacting us at

For further information about the n3rgy data service please refer to our Terms and Conditions.




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.


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. However, if we combine or connect anonymised data with your data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used by this privacy policy.

Purpose/activity Type of data Lawful basis for processing
To register you as a new user Identity




Your consent
To provide you with services Identity





Your consent

Necessary for our legitimate interests (to provide services to you in an appropriate manner)


To manage our relationship with you including notifying you of changes to the website or any services Identity



Marketing and Communication

Your consent

Performance of a contract with you

Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ services)

Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)

To administer and protect our business and this website including troubleshooting, data analysis and system testing Registration




Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
To deliver content and advertisements to you

To make recommendations to you about goods or services which may interest you.

To measure and analyse the effectiveness of the advertising we serve you.

To monitor trends so we can improve the website.




Marketing and Communications


Necessary for our legitimate interests (to develop our products/services and grow our business)





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;
  • HM Revenue & Customs, and any applicable regulator;
  • 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 us about our customers will be one of the transferred assets; and
  • 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;
  • where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK; or
  • if an appropriate safeguard has been put in place.


Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.


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 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.


Retention of Your Information

We retain your personal data for as long as necessary to fulfil the purposes we collected it for. In determining the appropriate retention periods, we take into account the following criteria:

  • our legal and regulatory obligations,
  • any relevant industry standards or codes,
  • the nature and sensitivity of the personal data and
  • the potential risk of harm from any unauthorised or unlawful processing, accidental loss, destruction of or damage to the personal data.

In some circumstances, we will anonymise your 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.

If you do not use your account for a period of [2] years then we will treat the account as expired and your data will be archived and may be deleted..



Your Rights

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

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;
  • request the transfer of your personal data to a third party;
  • request restriction of processing of your data; and
  • withdraw your consent at any time (where we are relying on consent to process your data)

However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.


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.




You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues.



Changes to Our Privacy Policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email.  Please check back frequently to see any updates or changes to our privacy policy.


Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to




Please see our Cookie Policy page for details of cookies used by us:

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 the Services may become inaccessible or not function properly.

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.


We use cookies in the following ways:

  • 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.