PRIVACY AND CONSENT POLICY

This Privacy and Consent Policy applies between you, the User of this Website, and In Home Displays Limited, the owner and provider of this Website. In Home Displays Limited takes the privacy of your information very seriously and are committed to protecting your personal data. This Privacy and Consent Policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website.

This Privacy and Consent Policy includes details of how we manage your personal data through our website, or support services, for example when you request information, purchase a product or request a product be joined to your smart metering network. It should be read alongside, and in addition to, our Terms and Conditions, which can be found at www.in-home-displays.co.uk.

Please read this Privacy and Consent Policy carefully.

Definitions and Interpretation

1. In this Privacy and Consent Policy, the following definitions are used:

2. In this Privacy and Consent Policy, unless the context requires a different interpretation: a. the singular includes the plural and vice versa;

b. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this Privacy and Consent Policy;

c. a reference to a person includes firms, companies, government entities, trusts and partnerships;

d. “including” is understood to mean “including without limitation”;

e. reference to any statutory provision includes any modification or amendment thereof;

f. the headings and sub-headings do not form part of this Privacy and Consent Policy.

Scope

3. This Privacy and Consent Policy applies only to the actions of In Home Displays Limited and Users with respect to this Website. It does not extend to any other websites that can be accessed from this Website

4. For purposes of the applicable Data Protection Laws, In Home Displays Limited is the “data controller”. This means that In Home Displays Limited determines the purposes for which, and the manner in which, your Data is processed. You can contact us if you have any questions about this Privacy and Consent Policy at contact@ihdl.co.uk or by mail to our registered address above.

Data Collected

5. We may collect the following Data, which includes personal Data, from you: a. Name, including first name, last name and title

b. Contact Information such as email address, delivery address, billing address and telephone number;

c. Financial information such as credit / debit card numbers for the purposes of transactions;

d. Meter (MPAN or MPXN) information relating to the installation address of our devices;

e. Consent data to verify and authenticate your agreement and right to allow us to “join” devices you purchase from us, where required. This may include proof of address, such as the MAC address of your existing in home display, or a recent utility bill or council tax bill stating the installation address

in each case, in accordance with this Privacy and Consent Policy.

Smart Energy Code and Consent – Required Data

6. We need to collect certain Data in order to perform the services you wish us to provide. If you fail to provide the necessary information, we may not be able to support the services you require. In this case, we may have to cancel a product order or the device(s) you have purchased from us will not be able to function.

7. We are required by the Smart Energy Code to gain unambiguous consent from you in order to connect our device(s) to your smart metering system. To satisfy these requirements, we will

request information to verify and authenticate that you are the registered energy consumer at the property. You will also be required to give your consent to connect our device(s) to your smart metering system and allow us to share necessary information with specific third parties to facilitate this process. This is described in the Energy Data Sharing Consent Document in clause 9 below. If you do not give this consent, or withdraw consent, we will be unable to “join” your device to your smart metering network and your device(s) will no longer function. 8. We use a third party contractor to help manage the connection of your device(s) to the smart metering system. We will only share necessary information for the installation of your devices.

How We Collect Data

9. We collect Data in the following ways: a. data given to us by you; and

b. data collected automatically.

Data That is Given to Us by You

10. In Home Displays Limited will collect your Data in a number of ways, for example: a. when you contact us through the Website, by telephone, post, e-mail or through any other means;

How We Collect Data

9. We collect Data in the following ways: a. data given to us by you; and

b. data collected automatically.

Data That is Given to Us by You

10. In Home Displays Limited will collect your Data in a number of ways, for example: a. when you contact us through the Website, by telephone, post, e-mail or through any other means;

b. when you make payments to us, through this Website or otherwise;

c. when you use our services;

d. to allow us to “join” your devices to your smart metering network in order to support the functionality of our device(s);

in each case, in accordance with this Privacy and Consent Policy.

Data That is Collected Automatically

11. To the extent that you access the Website, we will collect your Data automatically, for example: a. we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.

b. we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed “Cookies”.

Our Use of Data

12. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website or services. Specifically, Data may be used by us for the following reasons: a. internal record keeping;

b. to respond to customer queries;

c. to facilitate provision of services required to support the function of your purchased device(s)

in each case, in accordance with this Privacy and Consent Policy.

13. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).

Who We Share Data With

14. We may share your Data with the following groups of people for the following reasons: a. third party service providers who provide services to us which require the processing of personal data – to supply information necessary to satisfy regulatory authorities when supplying the requested service supporting product operation;

b. third party payment providers who process payments user payments and refunds made over the Website;

c. trusted third parties to host our website (?)

d. relevant authorities – only as and when required by law;

We require that all our third parties adhere to data protection law and respect the privacy of your personal data.

Keeping Data Secure

15. We will use technical and organisational measures to safeguard your Data, for example: a. access to your account is controlled by a password and a user name that is unique to you.

b. we store your Data on secure servers.

c. payment details are encrypted using SSL technology (typically you will see a lock icon or green address bar (or both) in your browser when we use this technology.

16. We are certified to ISO 27001. This family of standards helps us manage your Data and keep it secure.

17. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: contact@ihdl.co.uk.

18. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Data Retention

19. Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this Privacy and Consent Policy or until you request that the Data be deleted.

20. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

Your Rights

21. You have the following rights in relation to your Data: a. Right to access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.

b. Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.

c. Right to erase – the right to request that we delete or remove your Data from our systems.

d. Right to restrict our use of your Data – the right to “block” us from using your Data or limit the way in which we can use it.

e. Right to data portability – the right to request that we move, copy or transfer your Data.

f. Right to object – the right to object to our use of your Data including where we use it for our legitimate interests.

g. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: contact@ihdl.co.uk.

22. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.

23. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

24. Please note, if you withdraw consent for the use of our products, or of the information/Data required to provide our services, your device(s) will be unjoined from your smart metering network and may no longer function.

Links to Other Websites

25. This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This Privacy and Consent Policy does not extend to your use of such websites. You are advised to read the Privacy Policy or statement of other websites prior to using them.

Changes of Business Ownership and Control

26. In Home Displays Limited may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of In Home Displays Limited. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy and Consent Policy, be permitted to use the Data for the purposes for which it was originally supplied to us.

27. We may also disclose Data to a prospective purchaser of our business or any part of it.

28. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

Cookies

29. This Website may place and access certain Cookies on your computer. In Home Displays Limited uses Cookies to improve your experience of using the Website and to improve our range of products. In Home Displays Limited has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

30. All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.

31. Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling In Home Displays Limited to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.

32. This Website may place the following Cookies: