Privacy Policy

Gulf Gas and Power UK respects your privacy and is committed to protecting your personal data.  This privacy notice will let you know how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Please note the Glossary to understand the meaning of some of the terms used in this privacy notice.

Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Gulf Gas and Power UK collects and processes your personal data, including any data you may provide through this website when you make decision to switch your energy supply, are provided with an online account, make a purchase or interact with any of our marketing.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we use your data.

Controller

We, us or our is Gas and Power Limited (company number 09735925). Our address is Bowcliffe Hall, Bramham, West Yorkshire, England, LS23 6LP. When supplying Energy, we trade under the name Gulf Gas & Power UK. When we refer to Gulf Gas & Power UK, we are also referring to Gas & Power Limited. Gulf Gas & Power UK is the controller and responsible for this website.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the us using the details set out below.

Contact details

Our full details are:

Full name of legal entity: Gas and Power Limited

Email address: [email protected]

Postal address: Freepost GULF GAS AND POWER

Telephone number: 0800 830 3670

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, be happy to consider and assist you with any concern you may have so would be delighted if you might contact us in the first instance. Our Complaints Procedure can be found here.

Changes to the privacy notice and your duty to inform us of changes

 This version was last updated on 24th May 2018. Historic versions can be obtained by contacting us.

Please keep us informed if your personal data changes during your relationship with us. You can inform us of changes to your personal information by:

  • Our online webform
  • Our Customer services team
  • Writing to us

All these details can be found here.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  1. Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.
  2. Contact Data includes billing address, delivery address, email address and telephone numbers.
  3. Financial Data includes bank account and payment card details.
  4. Transaction Data includes details about payments to and from you.
  5. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  6. Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  7. Usage Data includes information about how you use our website, products and services.
  8. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for analytic purposes (for example to improve our website and make it more attractive and easier to use). Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.

For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

There may be occasion when Gulf Gas and Power UK collects Special Category Personal Data about you (if this is relevant it will only be in relation to any relevant health considerations). Special Category Personal Data would be used to support our understanding of whether the Priority Services Register is something you should be a part of.  Gulf Gas & Power UK is required by our regulator to update the Priority Services Register. For further information, please click here.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to switch your supply of Gas and or Electricity to Gulf Gas and Power UK). In this case, we will make every effort to contact you to gather such information, however should we fail we may have to cancel your switch; we will always notify you if this is the case at the time and you should be assured that this will not result in a loss of power / disconnection at the relating property.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • apply for our products or services;
  • create an account on our website;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us some feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources.

How 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 in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message.

You have the right to withdraw consent to marketing at any time by contacting us. For details of our policy, please click here.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us  if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

Purpose/Activity Type of data Lawful basis for processing
1 To register you as a new customer via our website Identity, Contact, Financial, Technical, Profile, Marketing Performance of a contract with you
2 To request a new meter reading Identity, Contact Legal or regulatory obligation
3 To produce and send you a bill or statement Identity, Contact, Financial, Transactional, Usage Legal obligation
4 To review your Direct Debit Identity, Contact, Financial, Transactional, Usage Legal or regulatory obligation
5 To set up a new agreement once your current agreement expires Identity, Contact, Financial, Transactional, Profile, Usage Legal or regulatory obligation
6 To move you to a default tariff Identity, Contact, Financial, Transactional Legal or regulatory obligation
7 To keep you updated with new products, services and promotions from Gulf Gas & Power UK Identity, Contact, Technical, Marketing, Usage Legal obligation, legitimate interests
8 To ask for feedback on our services Identity, Contact Legitimate Interest g.
9 To manage our relationship with you by sending you service updates or changes that will affect the products and services you use Identity, Contact, Financial, Transactional, Usage, Marketing Legal or regulatory obligation
10 To register you as a new customer via a Price Comparison Website Identity, Contact, Financial, Technical, Marketing Performance of a contract with you
11 To give you access to our online management tool, allowing you to provide meter readings, download bills, update details and access other self-service tools Identity, Contact, Financial, Transactional, Technical, Profile Legitimate interest
12 To give you a quote Identity Performance of a contract with you
13 To allow you to submit a customer services request Identity, Contact Legitimate Interest
14 To track your energy usage to allow us to forecast and better understand the way our customers use their energy Identity, Transactional, Technical, Usage Legal obligation, legitimate interests
15 To allow us to retain a record of your contact requests and actions necessary to service you in your contract with us (Tickets and account Demand) Identity, Financial, Contact Legitimate interest, contract
16 To be updated from the industry we accept and send a range of data flows to support taking over your supply, servicing you appropriately, Identity, Contact Contract, legitimate interests, legal obligation
17 A Contract is in place with a third-party service provide who support managing the above data flows Identity, Contact legitimate interest
18 Meter read schedule (GAS supply) is sent to our Meter Read Agent to request site visits Identity, Contact legal obligation, legitimate interest
19 Enrolment requests which are unable to be processed are reviewed and stored to attempt to register these customers.  Reasonable attempts will be made to enrol customers, which may involve contact through email and / or Telephone activity. Identity, Contact, Financial Contract
20 Where a customer is wishing to enrol with GGP UK and there is a rejection from a relevant industry body. Identity, Contact, Financial Contract
21 Where a customer has cancelled through a process of cooling off Identity, Contact, Financial Legitimate interest
22 Where a customer has wished to enrol with GGP UK and there has been an objection to the switch by the current supplier Identity, Contact, Financial Contract, legitimate interests
23 Details of our customer base are held and updated within our Customer Relationship Management system. Identity, Contact, Financial, Transactional Contract, Legitimate interests, Legal obligation

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising, customers can manage the way we communicate with them by logging into their My Gulf account.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will only receive marketing communications from us if you have specifically and explicitly requested so. You are fully in control of your consent preferences and at any time can view, change and withdraw your consent preferences in your My Gulf account. Whilst we give you this control over your preferences we will, as per our Consent Policy, review your preferences a minimum of annually and request that you provide further explicit consent on your chosen preferences.

Third-party marketing

As standard business practice Gulf Gas and Power UK does not share your personal data with any other company or organisation.  Should we wish to transfer your information anywhere else we will notify you of our intention to do so, the basis of this activity and request express opt-in and consent.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Cookies

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 this website may become inaccessible or not function properly. You can find out more about how we use cookies in our Cookies Policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table above.

  • Internal Third Parties as set out in the Glossary.
  • External Third Parties as set out in the Glossary.
  • Specific third parties listed

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

We do not transfer your personal data outside the European Economic Area (EEA).

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 addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can

By law we must keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see the Request Erasure section below for further information.

In some circumstances we may 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.

Your legal rights

Your legal rights are listed below. Please get in touch if you would like any additional information.

  • Access
  • Correction
  • Erasure
  • Processing
  • Processing
  • Transfer
  • Withdrawal of consent

If you wish to exercise any of the rights set out above, please contact us.

No fee required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights).

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary

Lawful Basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third Parties

Internal Third Parties

Other companies Gulf Gas and Power UK use as joint controllers or processors and who are based in the UK and provide IT and system administration services and undertake group level reporting.

External Third Parties

  • Junifer Systems acting as processors based in the UK who provide IT and system administration services.
  • Utiligroup acting as processors or joint controllers based in the UK who provide consultancy, managed services, data services and reporting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • Barclays Bank – to set up BACS Direct Debits, Direct Credits and payments
  • Bottomline – to validate your banking details
  • CNG – to provide gas supply services to your property

Your Legal Rights

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. You can access our Subject Access Policy here.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Correction to personal data can be done here

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. You can access our Withdrawal of Consent Policy here.

 

 

Gulf Gas & Power UK Privacy Policy May 2018 v1.0