Ginger Energy Limited (“Ginger”) understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our stakeholders – clients, those we invoice on behalf of our clients, suppliers, partners and employees – and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Ginger has a separate Privacy Notice for employees covering the personal data we collect and use for them.
1. Information About Ginger
Ginger Energy Limited.
A limited company registered in England under company number 06889612.
Registered address: 4 The Cloisters, 12 George Road, Edgbaston, Birmingham B15 1NP.
Main trading address: 4 The Cloisters, 12 George Road, Edgbaston, Birmingham B15 1NP.
VAT number: GB973681381.
Representative: Company Secretary.
Email address: privacy@gingerenergy.co.uk.
Telephone number: 0345 307 3433.
Postal address: 4 The Cloisters, 12 George Road, Edgbaston, Birmingham B15 1NP.
We are subject to regulation:
In respect to our energy procurement / brokerage activity: Ombudsman Services
In respect to our multi-tenancy block utility invoicing services: Ofgem, Department for Energy Security and Net Zero (DESNZ).
We are members of The Association for Decentralised Energy (ADE), The Association of Residential Management Agencies (ARMA), the Institute of Workplace and Facilities Management (IWFM), Confederation of School Trusts (CST).
2. What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
3. What Is Personal Data?
Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
4. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 12
b) The right to access the personal data we hold about you. Part 11 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 12 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 12 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 12.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice office.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office – contact details are provided in Part 13 below. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the instructions in Part 12 below.
5. What Personal Data Do You Collect and How?
We may collect and hold some or all of the personal [and non-personal] data set out in the table below, using the methods also set out in the table. We do not collect any ‘special category’ or ‘sensitive’ personal data or personal data relating to children or data relating to criminal convictions and/or offences.
| Data Collected | How We Collect the Data |
| Identity Information including: Name; title (and by inference possibly gender). |
From our clients in fulfilment of our contractual obligations; from individuals via email / the Ginger portal / phone. |
| Contact information including: Email address, mobile / phone number. In respect to the multi-tenancy blocks we invoice on behalf of our clients: Home address; invoiced property address for owners / occupiers. |
From our clients in fulfilment of our contractual obligations; from individuals via email / the Ginger portal / phone. |
| Business information including: Business name, business contact details (email, web site URL, phone number), key person details including job title, profession. |
Networking, business related social media (e.g. LinkedIn), internet based research, marketing. |
| Payment information: We use payment transactions to determine the utility account to which the payment relates. We use third parties to process Direct Debit and card payments and only hold records as to method of payment. |
We take a small number of card payments by phone. Card details are not recorded or stored. Otherwise all payment details are passed directly to our specialist Direct Debit and card payment service providers and all processing is performed on their systems. |
| Data from third parties: In addition to the client data referred to above: Utility meter assets. Meter read and/or consumption data. Client’s utility contract details (pricing, conditions, term, etc.) |
From specialist metering companies, utility Suppliers, utility industry data processors (e.g. Retail Energy Code Company Ltd., Electricity Central Online Enquiry Service). |
|
Technical data from any visits to our web site or portal: Technical information, may include the internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); pages 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. |
This information is automatically collected by the IT systems running our website / portal and business applications and is anonymised. See also ‘Use of Cookies’ below. |
6. Use of Cookies
What are cookies?
Cookies are simple text files that are stored on your computer or mobile device by a website’s server. Each cookie is unique to your web browser. It will contain some anonymous information such as a unique identifier, website’s domain name, and some digits and numbers.
What types of cookies do we use?
Necessary cookies
Necessary cookies allow us to offer you the best possible experience when accessing and navigating through our website and using its features. For example, these cookies let us recognize that you have created an account and have logged into that account.
Functionality cookies
Functionality cookies let us operate the site in accordance with the choices you make. For example, we will recognize your username and remember how you customized the site during future visits.
Analytical cookies
These cookies enable us and third-party services to collect aggregated data for statistical purposes on how our visitors use the website. These cookies do not contain personal information such as names and email addresses and are used to help us improve your user experience of the website.
How to delete cookies?
If you want to restrict or block the cookies that are set by our website, you can do so through your browser setting. Alternatively, you can visit www.internetcookies.com which contains comprehensive information on how to do this on a wide variety of browsers and devices. You will find general information about cookies and details on how to delete cookies from your device.
7. How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we will or may use your personal data, and our lawful bases for doing so:
| What We Do | What Data We Use | Our Lawful Basis |
| Administering our business. | Business information, identity and contact information for key client and prospect contacts. | Legitimate interests of Ginger – administering the business relationship with our contracted clients and to enable us to market our services to prospective clients |
| Supplying our services to our procurement / brokerage / energy consultancy clients. | Business information, identity and contact information for key client and prospect contacts, utility Supplier contract information. | Legitimate interests of Ginger – to fulfil our obligations to our contracted clients. |
| Supplying our billing services to our multi-occupancy block management clients. | Business information, identity and contact information for key client and prospect contacts, utility Supplier contract information. Contact information for the owners / occupiers of the properties invoiced on behalf of clients. |
Legitimate interest of our clients / our contractual obligation – we are contracted by our clients to invoice their leaseholders (and in some cases to provide copy invoices to the leaseholders’ sub-tenants and letting agents) under the terms of the leasehold agreement between the leaseholder and the freeholder of the property. |
| Managing payments for our services on behalf of our multi-occupancy block management clients | Our systems record payment methods, and payments received from owners / occupiers in respect to their utility invoices, and hold transactional data (invoices, payments) to enable balance of account / statements to be created. All payment are processed by specialist payment organisations – Access Paysuite for Direct debits and Barclaycard for card payments – Ginger do not store any bank account or card information related to leaseholders or their sub-tenants. |
Legitimate interest of our clients / our contractual obligation – we are contracted by our clients to collect payments from their leaseholders (and in some cases the leaseholders’ sub-tenants) for the utilities we invoice on their behalf. |
| Communicating with you. | Business information, identity and contact information for key client and prospect contacts, utility Supplier contract information. Contact information for the owners / occupiers of the properties invoiced on behalf of clients. Emails. Phone calls through our company system are recorded. |
Legitimate interest of Ginger – to fulfil our contractual obligations to clients and in the interests of good communication with all interested parties. |
| Supplying you with information by email or post or telephone communication that you have requested or (in the case of the portal) opted-in-to (you may opt-out of portal access at any time by emailing us at billingteam@gingerenergy.co.uk). | Whatever information you legitimately request plus and we believe we may share, and general information and updates. | Your consent and legitimate interest of our clients. |
| Ensuring our platforms are meeting our requirements for service delivery. | Technical data from visits to our web site or portal. | Legitimate interest of Ginger – to ensure we provide our clients with an effective service. |
In respect to our clients / prospects (but excluding the owners / occupiers of our clients’ multi-occupancy blocks management with whom we interact through our utility billing services) with your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email or telephone or text message or post with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will not share your personal data with any third parties for marketing purposes.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 12.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
8. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
| Type of Data | How Long We Keep It |
|
Identity Information for client businesses and their key contacts: Business name, business contact details (email, web site URL, phone number), key person details including title (and by inference potentially gender), job title, email address, mobile number, profession. |
Indefinitely unless requested to remove. |
| Procurement / brokerage utility supply data including Supplier contracts: Includes supply addresses and contact details, meter asset details, reads / consumption, Supplier contracts. |
Indefinitely unless requested to remove. |
| Billing service owner / occupier information: For owners / occupiers of our clients’ blocks: Home address; invoiced property address, meter asset details, meter reads / consumption, invoices, statements, payment transactions details, (direct debit / bank / card). |
For the duration of the relevant client contract plus one year (to allow client to transfer service responsibility to another supplier). Where the transaction details are required to be kept for statutory purposes for our financial records we will keep them indefinitely, or for at least the statutory period – currently 6 years after the end of the financial year the transaction relates to. |
| Other Ginger stakeholder information: Includes contact information for suppliers to Ginger and other businesses or individuals who work with Ginger in developing or delivering services. |
Indefinitely unless requested to remove. |
| Emails For general communications with all stakeholders, delivery of key documents etc. |
Indefinitely unless requested to remove. |
| Telephone recordings. For any calls (incoming / outgoing) through the Ginger telephone switch. Note: Recordings are suspended for card payments. |
72 months. |
9. How and Where Do You Store or Transfer My Personal Data?
We will only store your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
10. Do You Share My Personal Data?
We may share your personal data third parties for the following specific reasons only:
If we sell, transfer, or merge parts of our business or assets, or our client ends a service contract and transfers the service responsibility to another company, your personal data may be transferred to a third party. Any new owner of our business, or the new service provider, may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
We may partner or sub-contract with the following third parties to supply services.
| Recipient | Activity Carried Out | Sector | Location |
| Utility Suppliers. All UK licenced gas, electricity and water supply companies. Data controllers. |
Ginger acts as a broker and intermediary, the final supply contracts for clients being with the Suppliers. | Energy. | All UK Licensed Suppliers |
| Aggregators. UK based organisations who secure utility supply contracts for SME business consumers. Data controllers. |
For some SME clients the most effective route to securing an appropriate supply contract is to use an aggregator who ‘bundles’ the requirements of a number of end users to gain better price points. | Business consultancy. | Tickd Ltd 30-34 Hounds Gate, Nottingham, NG1 7AB UCR Consultants Ltd Crescent House, 40 Regent Road, Leicester, LE1 6YJ Telex UK Ltd Cobalt 3.1, Silver Fox Way, Cobalt Business Park, Newcastle Upon Tyne, NE27 0QJ |
| Water supply brokerage. Telex UK Ltd Data controller. |
Ginger’s partner in the provision of water supply brokerage and procurement services. | Telex UK Ltd Cobalt 3.1, Silver Fox Way, Cobalt Business Park, Newcastle Upon Tyne, NE27 0QJ |
|
| Debt collection services. Utilidebt Ltd. Data processor. |
Utilidebt undertake collection activities for overdue utility payments from our clients’ leaseholders (and occasionally on instruction from the leaseholder, their sub-tenants). This will include Dunning letters, emails, phone contact, and occasionally disconnection of supply. | Business consultancy. | Utilidebt Ltd. 4 The Cloisters, 12 George Road, Edgbaston, Birmingham B15 1NP. |
| Document print and mailing services. Checkprint Ltd. Data processor |
Checkprint print and post invoices and statements for owners / occupiers in the blocks we service for our clients where we have no email address. | Printing services | Checkprint Ltd. 1 Alan Bray Close, Dodwells Bridge Industrial Estate, Hinckley, Leicestershire, LE10 3BP |
| Cloud datacentre services. Microsoft Ireland Operations Limited Data processor |
Microsoft provide secure hosting services for our business applications in a UK datacentre that is certified to ISO27001 | Microsoft Ireland Operations Limited One Microsoft Place, South County Business Park, Leopardstown, Dublin 18 D18 P521 Ireland |
|
| Direct Debit mandate services. Access Paysuite Limited Data processor |
Processing Direct Debit mandates and collection instructions. | Financial services – regulated by the FCA. | Access Paysuite Ltd., The Old School, School Lane, Stratford St. Mary, Colchester, Essex, CO7 6LZ |
| Card payment services. Barclaycard Data processor |
Processing card payments. | Financial services – regulated by the FCA. | Barclaycard Barclays Bank plc, 1 Churchill Place, London E14 5HP |
If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
11. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 12. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 10 days and in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
12. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Company Secretary):
Email address: privacy@gingerenergy.co.uk
Telephone number: 0345 307 3433.
Postal Address: Ginger Energy Limited, 4 The Cloisters, 12 George Road, Edgbaston, Birmingham B15 1NP.
13. Complaints
If you have any concerns about our use of your personal information, you can make a complaint to us using the contact details provided in Part 12 above.
If you remain unhappy with how we have used your data or responded to your requests, you have the right to complain to the Information Commissioner’s Office (ICO).
Address for the ICO:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk.
14. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available on the Ginger web site (https://gingerenergy.co.uk/privacy-policy). This Privacy Notice was last updated on 13.06.2024.