Sentri Ltd will use your personal data to fulfil our contractual, business and legal obligations, and to provide information about our services, along with associated information connected to the energy industry.
When we talk about data and personal data we mean any data which identifies you or which could be used to identify you such as your name, address and any contact details.
Who is responsible for your data?
Sentri Ltd is responsible for your data.
Our registered address is 90 High Street, Kelvedon, Essex, CO9 5AA. We are registered as a UK company under company number 3839120 and our registration with the Information Commission’s Office is Z5084677.
We are the data controller and processor of the data which we collect, we control the ways your personal data are collected and the purposes for which your personal data are used.
What data do we collect?
Our business predominately involves business to business communication and dealings with individuals within companies and organisations that are or may be interested in the services that we provide. We do not specifically target contact with individual consumers however, there are instances that we are in communication with individuals that are not connected with a company or organisation, for instance sole traders. In this respect we would regard the individual to be a business customer.
Paying subscribers to some of the services offered by Sentri Ltd require registration by an on-line form and as part of the registration process data is collected for the contact at the company or organisation, or the individual that is participating in the service.
Throughout the above we do not collect or hold any forms of sensitive personal data, no special category data, and no criminal offence data.
a) Companies & Organisations
The data that we collect, and hold, is only for the types of companies and organisations that would be interested in and have or may have use our services. This includes but is not limited to Utility Companies, System Operators, Consultants, Investment Funds and Fund Managers, and Legal and other advisory firms. Part of the company or organisation data we hold would include contacts within the company that are owners, employees or in some way connected to the companies and organisations that we are working with, communicating with, or providing information to.
The data that we would collect, and hold, would include some or all the following:
– The name of the company or organisation
– The address and postcode of the company or organisation
– The geographical region the company or organisation works in
– The type of business the company or organisation is
– The first and last name of a contact or contacts at the company or organisation
– A contact email address of the contact at the company or organisation
– The telephone or/and mobile number for the contact at the company or organisation
– The job role of the contact at the company or organisation
b) Individual contacts
As noted above we do not specifically target contact with consumers and primarily focus on business to business communication. However, there are situations where we would collect and hold data for individuals in particular sole traders interested in our services.
The data that we would collect, and hold, would include some or all the following:
– The first and last name of the individual
– Any trading name used
– The type of business being conducted
– A contact email address of the individual
– The telephone or/and mobile number of the individual
– The address and postcode of the individual
How have we collected the data that we hold?
The data that we have collected, and hold, has come from several sources which are listed below.
– Previous and existing customer contracts
– Business meetings
– Direct contact and enquiries by phone or email
– Contacts though our website
– Research of relevant business contacts on the internet and openly accessible directories
How do we use the data that we hold and what are the legal grounds for processing?
We use the data we collect from you for a range of different business purposes and according to different legal grounds of processing. The following is a summary of how and according to which legal grounds we use your data.
Data processed under the legal grounds of contract can be for companies, organisations or individuals collected based on us providing sale of our services or the enquiry into doing so. This data is held and processed to allow us to deliver our services, promote other services of interest and supply information associated with the energy industry.
Data processed under the legal grounds of consent covers data where the company, organisation or individual has specifically provided us their consent to process their data. Consent mainly covers data that has come from specific requests to be added to our mailing lists. These consents would either be via direct communication to us or through an enquiry from our website or via a third party. Our mailing list is only used for emailing to promote our services, inform you of company and industry related news, and supply associated information connected to the energy industry.
c) Legitimate Interest
Data processed under the legal grounds of legitimate interest covers any data that is not contractually sourced or not covered by specific consent. This data is only for companies, organisations and sole traders as the contacts and data collected is sourced specifically for business to business communication. The processing of this data serves our own commercial interests. In many cases it is also intended to serve the commercial interest of the recipient too. Processing involves us promoting our services, informing you of company an industry related news, and supplying associated information connected to the energy industry. The processing of this data is done in ways that would be reasonably expected by the recipient and has minimal privacy impact.
How do we protect your data?
We protect your personal data against unauthorised access, unlawful use, accidental loss, corruption or destruction. Access is limited to individuals working for Sentri Ltd and only where their working role requires access to the specific data held.
Data storage is protected by password, both on the computers that hold the data and software used to operate it. Likewise, any data held within electronic address books or on mobile devices is also password protected. Our subscriber list and user password control system is held with a specialist services provider who manages our website and who have their own data protection procedures with password protected access.
Do we share your data or send it elsewhere?
Sentri Ltd does not share any of the personal data that we hold with any other companies, organisations or third parties unless express consent been given. Such consent would typically be requested where a subscriber attendee or service provider to a Sentri Ltd event seeks to make contact with another by phone or email.
What are your rights?
You have the right to be informed about our holding and use of your data as we are setting out in this policy. You are entitled to access and see copies of all personal data held by us and to amend, correct or delete any data that you wish. You can also limit, restrict or object to the processing of your data. You can contact us as described in the following section to request copies of any data that we hold. You can also use this process to request erasure of your data.
You have the right to have any incorrect or inaccurate data rectified. We will do this if you advise us that data needs to be corrected or if during communications with you we become aware that data we hold is incorrect. If you have entered into a contract and purchased services from Sentri Ltd then even if you ask for data erasure we may need to retain some data associated with the purchase and contract legally for a specific period. This would be to either validate any claim in connection with the service or to comply with any accounting requirements associated with the contract and purchase. We would advise if this was the case and for how long it would be retained at the point data erasure is requested.
If you have given us your consent to use your data by agreeing to receive our marketing emails, you can withdraw your consent whenever you like. This can be done by unsubscribing from any marketing messages that we send or by contacting us directly to request removal or full data erasure. Please note that even if you withdraw your consent, we can still rely on the consent you gave as the lawful basis for processing your data before you withdrew your consent.
You can object to our use of your data where we rely on our legitimate interests to do so. The legitimate interests we use to process your data are explained in the previous section ‘What are the legal grounds for our processing of your data?’. You can unsubscribe from our mailing list via any message that you have received. Or you can contact us and request removal of your data from our marketing list or for complete removal of all your data from our systems.
When you get in touch, we will come back to you and action any requests as soon as possible.
Unsubscribing from mailing lists will be done as soon as received and before any further mailings are sent.
Erasure of data will be completed as soon as possible but may require us to confirm back to you any justified reason and data details that we legally or contractually must retain. If your request is for copies of any data that we hold then this will be provided within one month as legally required. There is no charge for data requests, however, we may ask you to verify your identity before we provide any information to you.
You have the right to make a complaint about our processing of your data, either directly with ourselves or the supervisory authority responsible for the protection of personal data. Details of how to do this are included in the following section ‘Making a complaint’.
How long do we keep your data for?
We retain your data for as long as necessary for the purposes that it was collected or for other essential purposes such as complying with our legal and accounting obligations, resolving disputes and providing the services.
Requests to unsubscribe your details from mailing lists will not necessarily remove all personal data from our background systems as we would keep some details on file to ensure that your request is followed in the future and your details are not reinstated. The data we retain will only be enough to identify you as a previous contact who has unsubscribed from our list.
If a specific request is received to remove all your data from our systems, then we will do this complying with your right to request erasure unless this conflicts with any of our legal or accounting obligations.
What to do if your details change?
Sentri Ltd are legally required to ensure that the data that we hold is accurate and up to date. If we discover that data is incorrect then we will correct it or remove it as necessary. If your details change and you wish to continue to hear from us, then contact us as detailed bellow and we will update the data we have recorded. Likewise, if your situation changes (change of job role or company) and the information that we provide is no longer relevant then contact us and we will remove your details from further contact in the future.
Making a complaint
If you have any complaints concerning Sentri Ltd’s processing of your personal data, please email us at firstname.lastname@example.org or write to our registered address, Sentri Ltd, 90 High Street, Kelvedon, Essex, CO9 5AA.
We will always act upon any complaint or request for removal of personal data but please note that you have the right to lodge a complaint with the supervisory authority which is responsible for the protection of personal data. The Information Commissioner’s Office is the UK body responsible for protection of personal data, they can be contacted by telephone on 0303 123 1113 or by their website www.ico.org.uk.
You can contact us at Sentri Ltd by phone on 01473 780933, by email at email@example.com or by writing to us at Sentri Ltd,90 High Street, Kelvedon, Essex, CO9 5AA.
24 May 2018