INTRODUCTION

Under the 2018 General Data Protection Regulations Inver is required to give you a statement of our data policies and your rights. These are contained in this statement.

Under the new regulations, Inver is defined as a data controller in respect of our customers and suppliers’ Personal Data and so Inver is responsible for ensuring that it uses your Personal Data in compliance with data protection law.

At Inver we respect the privacy of our customers and suppliers and we are committed to taking all appropriate steps to keep your Personal Data secure. This Privacy Statement governs the handling of Personal Data by Inver in the course of carrying on commercial activities.

In this Statement:

(“Inver”), (“We”) or (“Us”) means Inver Energy;

(“Customer and supplier”), (“you”) means all Inver customers and suppliers that are using Inver services or provide services to Inver.

(“Personal Data”) means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, Inver (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of Inver or any other person in respect of an individual.

(“Regulatory Body”) means any regulatory body by which Inver is or becomes regulated.

THE TYPES OF PERSONAL DATA WE COLLECT

Some of the products and services offered by Inver require us to obtain Personal Data about you. Inver will also obtain Personal Data from some suppliers in order to receive certain goods or services. In the course of and in connection with the provision of those good or services, Inver will collect and process the following Personal Data about you:

Information that you provide to Inver.

Such information may include (by way of non-exhaustive list):

  • basic Personal Data (such as name; age; address; gender; nationality; citizenship; address; telephone numbers; email address; date of birth);
  • financial information if you are applying for credit or seeking some other financial arrangements (such as advisor details; investment details; banking details; employment status; and financial details; income, credit history, debts and liabilities);
  • if there are tax implications related to your financial activities, your social insurance number or other tax identification number and details of tax residency;
  • Personal Data provided by you in the context of us carrying out background checks, including in relation to anti money laundering, regulatory and tax and know your client checks (such as Personal Data included in identification documents, details of criminal records and sanctions).

Information Inver collects or generates about you:

  • a file with your contact history to be used for enquiry purposes so that we may ensure that you are satisfied with the services which we have provided to you;
  • details to ensure procurement services;
  • records of telephone calls to protect you and us from fraud.

Information Inver obtains from other sources:

  • information obtained from credit references agencies for conducting affordability checks;
  • data obtained from credit insurance companies in order to analyse the credit worthiness and financial stability;
  • details obtained from banks and governmental agencies to conduct anti money laundering checks.

If you visit www.Inverenergy.com cookies are used to collect technical information about the services that you use. This could include device-specific information, your navigation throughout the site, and other technical and browsing preferences including your location and entry point to site. Other Personal Data is not collected on the website.

COOKIES

Cookies are small text files that may be placed on your browser when you visit our Site. Cookies are used primarily for administrative purposes, to improve your experience with our Site. For instance, when you return to the Site after logging in, cookies provide information to the Site, including personal data, so that the Site will remember who you are. Our Site uses cookies primarily to capture anonymous analytics used to improve our Site experience and performance. This includes compiling statistical information concerning, among other things, the frequency of use of our Site, the pages visited, and the length of each visit, as well as information about your computer, operating system, browser, language, and country. We do not use cookies to store any personal data that could be read or understood by others.

Using the settings of your Internet browser, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. Consult your browser Help menu to learn the correct way to modify your cookies. If you choose to turn off cookies, you may not have access to certain features of our Site. You may at any time delete any cookies set by using the relevant option of your Internet browser or by deleting the cookies on your hard drive.

We use the following cookies:

Name: Google Analytics

Purpose: Google Analytics is a web analytics tool that helps us to understand how our users engage with our website and so allows us to better tailor our website to our user’s needs. The tool uses a cookie in order to evaluate use of content and compile reports for us on activity on our website.

Further Information: https://tools.google.com/dlpage/gaoptout

Name: Lead Forensics

Purpose: Lead Forensics identifies public IP addresses of visitors to our website via a line of Java script inserted into the webpages. The IP address is matched against the organisation registered to that IP address. (Only corporate information is held in the Lead Forensics database, so that individuals are not identified.) This information is used by our business for follow up marketing with relevant individuals at the organisations.

Further Information: If you do not want visitors from your IP address to our website to be tracked by Lead Forensics, please email us at info@inverenergy.com

HOW WE USE YOUR INFORMATION

Your Personal Data may be stored and processed by Inver including in the following ways and for the following purposes:

  • to inform you about news and information relating to our business – including product updates;
  • to assess your application for Inver’s products and services;
  • to understand your needs and interest;
  • to manage our relationship with our customers and suppliers;
  • to analyse and improve our services;
  • for the management and administration of our business;
  • in order to comply with and in order to assess compliance with applicable law, rules and regulations (including tax reporting purposes pursuant to tax legislation), voluntary codes we decide to adopt, or good practice, internal policies and procedures; or
  • to confirm and verify an individual’s identity (this may involve the use of a credit reference agency or other third party acting as our agents) and to conduct due diligence. We will also screen against publicly available government and/or law enforcement agency sanctions lists.
  • to detect, investigate and prevent fraud and other crimes or malpractice. For the purpose of, or in connection with, any legal proceedings (including prospective legal proceedings), for obtaining legal advice or for establishing, exercising or defending legal rights;
  • for the administration and maintenance of databases storing Personal Data; and
  • to comply with our contractual obligations.

Inver is entitled to use your Personal Data in these ways (at least one of the following need to apply):

  • in order to perform its contractual obligations with you (for example, in order to manage your orders and verify the information you provide to us);
  • if Inver has obtained your consent;
  • in relation to its legal or regulatory obligation that has to discharge;
  • in order to establish, exercise or defend its legal rights or for the purpose of legal proceedings;
  • for Inver’s legitimate business and proprietary interests such as:
    • allowing Inver to effectively and efficiently manage and administer the operation of its business;
    • maintaining compliance with internal policies and procedures; and
    • for internal research purposes.

DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES

We share personal information among our affiliates, business units and third-party independent suppliers, whose services are integral to the services we offer, but only in circumstances where such sharing conforms to law and our policies, in the circumstances outlined below:

  • the management and administration of Inver’s business (including the management of your orders) and the administration of the database which stores personal data;
  • assessing compliance with its applicable laws, rules and regulations, and internal policies and procedures across Inver.

Inver may also share your Personal Data outside of Inver for the following purposes:

  • with third party agents, service providers and contractors for the purposes of providing services to us (for example, Inver’s accountants, auditors, professional advisors, IT and communications providers). These third parties will be subject to confidentiality requirements and they will only use your Personal Data as described above.
  • to the extent required by law, for example if Inver is under a duty to disclose your Personal Data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements), or to establish, exercise or defend its legal rights. This may include disclosure to Regulatory Bodies;
  • as part of a transaction, for example if Inver sells any of its business or assets, in which case Inver may need to disclose your Personal Data to the prospective buyer for due diligence purposes;
  • if Inver is acquired by a third party, in which case the Personal Data held by us about you will be disclosed to the third party buyer.

Inver will not share your data with third parties to get value from the data, for instance selling as marketing lists.

HOW WE SAFEGUARD YOUR INFORMATION

Inver has controls in place to maintain the security of our information and information systems. Files are protected with safeguards according to the sensitivity of the information contained therein. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where Personal Data is gathered, processed or stored is limited to authorised employees.

As a condition of employment, Inver employees are required to follow all applicable laws and regulations, including in relation to data protection law. Access to Personal Data is limited to those employees who need it to perform their roles. Unauthorised use or disclosure of confidential client information by an Inver employee is prohibited and may result in disciplinary measures.

When you contact an Inver employee about your file, you may be asked for some Personal Data. This type of safeguard is designed to ensure that only you, or someone authorised by you, has access to your file.

RETENTION OF PERSONAL DATA

How long Inver will hold your Personal Data for will vary and will be determined by the following criteria:

  • the purpose for which Inver is using it – Inver will need to keep the data for as long as is necessary for that purpose; and
  • legal obligations – laws or regulation may set a minimum period for which Inver has to keep your Personal Data.

YOUR RIGHTS

You have a number of legal rights in relation to the Personal Data that Inver holds about you. These rights include:

  • the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which Inver holds about you;
  • the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that Inver may still be entitled to process your Personal Data if it has another legitimate reason (other than consent) for doing so;
  • in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that Inver transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided to Inver;
  • the right to request that Inver rectify your Personal Data if it is inaccurate or incomplete;
  • the right to request that Inver erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask Inver to erase your Personal Data but Inver is legally entitled to retain it;
  • the right to request that Inver restrict its processing of your Personal Data in certain circumstances. Again, there may be circumstances where you ask Inver to restrict its processing of your Personal Data but Inver is legally entitled to refuse that request; and
  • the right to lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by Inver.

You can exercise your rights by contacting Inver using the details listed in paragraph below.

You can find out more information about your rights by contacting the Office of the Data Protection Commissioner, or by searching their website at https://dataprotection.ie

QUESTIONS AND CONCERNS

If you have any questions or concerns about Inver’s handling of your personal Data, or about this Statement, please contact our Privacy Officer using the following contact information:

Email Address: privacy@Inverenergy.com