1.1 We are committed to safeguarding the privacy of our website visitors and other individuals for whom we hold personal information; in this policy we explain how we will treat your personal information.
2. Collecting personal information
2.1 We may collect, store and use the following kinds of personal information:
(a) information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths);
(b) information that you provide to us when registering with our website (including your email address);
(c) information that you provide when completing your profile on our website (including your name, telephone number, business name, business postcode);
(d) information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (including your name and email address);
(e) information that you provide to us when using the services on our website, or that is generated in the course of the use of those services (including the timing, frequency and pattern of service use);
(f) information relating to any purchases you make of our goods and/or services or any other transactions that you enter into through our website or otherwise (including your name, address, telephone number, email address);
(g) information that you post to our website for publication on the internet (including your user name, your profile pictures and the content of your posts);
(h) information contained in or relating to any communication that you send to us or send through our website (including the communication content and metadata associated with the communication);
(i) any other personal information that you choose to send to us;
(j) information provided to us when you or your company engages us to provide services;any other personal information that you choose to send to us;
2.2 Before you disclose to us the personal information of another person, you must obtain that person’s consent to the disclosure and you confirm to us that you are entitled to provide us with that person’s personal information and that the disclosure is fair. The processing of that personal information in accordance with this policy and you confirm that you have informed the person of the terms of this policy.
3. Using personal information
3.1 Personal information submitted to us through our website or otherwise will be used for the purposes specified in this policy on the relevant pages of the website or in any other documentation that we provide to you as relevant.
3.2 We may use your personal information to:
(a) administer our website and business;
(b) personalise our website for you;
(c) enable your use of the services available on our website;
(d) send statements, invoices and payment reminders to you, and collect payments from you;
(e) send you non-marketing commercial communications;
(f) send you email notifications that you have specifically requested;
(g) send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);
(h) send you marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);
(i) provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information);
(j) deal with enquiries and complaints made by or about you relating to our website;
(k) keep our website secure and prevent fraud;
(l) administer and manage your account, including but not limited to, for market research, billing and providing up-to-date information on water, associated waste efficiency and safety issues;
3.3 If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the licence you grant to us.
3.4 Your privacy settings can be used to limit the publication of your information on our website, and can be adjusted using privacy controls on the website.
3.5 We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party’s direct marketing.
4. Our lawful basis for using personal information
4.1 We will only use your personal information where we have a lawful basis under data protection legislation, including where:
(a) we have your consent (if consent is needed);
(b) we have a contract with you and need your personal information to perform that contract or to take steps to enter into a contract with you;
(c) we need to use your personal information to comply with legal obligations; or
(d) we have legitimate interests to use your personal information for administration of your account, only where there is no disadvantage to you.
4.2 Where you have given us consent to use your personal information, you may withdraw that consent at any time by contacting us at Data Protection, Brightwater Services Ltd, Suite 7 – First Floor, Stuart House, Eskmills, Station Road, Musselburgh, EH21 7PB.
4.3 Where we use your personal information in pursuit of legitimate interests, you may object to such use by contacting us at Data Protection, Brightwater Services Ltd, Suite 7 – First Floor, Stuart House, Eskmills, Station Road, Musselburgh, EH21 7PB.
5. Disclosing personal information
5.1 We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy. This includes, but is not limited to, IT suppliers, cost/efficiency consultants, the water industry regulator (the Water Industry Commission for Scotland), the water industry central systems (CMA Scotland), the water industry Wholesaler and network owner (Scottish Water).
5.2 In order to process your application to engage Brightwater Services Ltd as a service provider, we will supply your personal information to credit reference agencies (CRAs) and they will give us information about you, such as about your financial history. We do this to assess creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and prevent criminal activity. We will also continue to exchange information about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your information with other organisations. The identities of the CRAs, and the ways in which they use and share personal information, are explained in more detail at http://www.experian.co.uk/crain/index.html
5.3 We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.
5.4 We may disclose your personal information:
(a) to the extent that we are required to do so by law;
(b) in connection with any ongoing or prospective legal proceedings, debt recovery or tracing;
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
(d) to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
5.5 Except as provided in this policy, we will not provide your personal information to third parties.
6. International data transfers
6.1 Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.
6.2 Information that we collect may be transferred to the following countries which do not have data protection laws equivalent to those in force in the European Economic Area: the United States of America.
6.3 Where we transfer personal information outwith the European Economic Area, we will ensure that adequate safeguards are put in place to protect your personal information before the transfer. Such safeguards include:
(a) for transfers to the United States of America, we will ensure that the recipient of the personal information is registered under the US-EU Privacy Shield;
(b) ensuring that the country to which your personal information will be transferred has been deemed “adequate” by the European Commission; or
(c) entering into standard contractual clauses approved by the European Commission with the recipient of the personal information.
6.4 Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others but will put in place appropriate security measures and safeguards where possible.
7. Retaining personal information
7.1 This Section 7 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.
7.2 Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
7.3 Notwithstanding the other provisions of this Section 7, we will retain documents (including electronic documents) containing personal information:
(a) to the extent that we are required to do so by law;
(b) if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
8. Security of personal information
8.1 We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
8.2 We will store all the personal information you provide on our secure (password- and firewall-protected) servers.
8.3 All electronic financial transactions entered into through our website will be protected by encryption technology.
8.4 You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
8.5 You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).
9.1 We may update this policy from time to time by publishing a new version on our website.
9.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
9.3 We may notify you of changes to this policy [by email or through the private messaging system on our website].
10. Your rights
10.1 You have certain rights in relation to your personal information under data protection legislation, including the right to:
(a) request us to provide you with any personal information we hold about you; provision of such information will be subject to the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address);
(b) ask us to correct or complete the information that we hold about you if you believe that such information is inaccurate or incomplete;
(c) object to us using your personal information for specific purposes, for example, for marketing purposes;
(d) ask us to restrict using your personal information for specific purposes;
(e) request that we delete the personal information that we hold about you;
(f) obtain certain of the personal information that we hold about you for your own use; and
(g) know about any automated decision-making and profiling.
10.2 We will consider any requests we receive from individuals in accordance with the terms of data protection legislation.
11. Third party websites
11.1 Our website includes hyperlinks to, and details of, third party websites.
11.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
12. Updating information
12.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
13. About cookies
13.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
13.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
13.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
13.4 Cookies can be used by web servers to identify and track users as they navigate different pages on a website and identify users returning to a website.
14. Analytics cookies
14.1 We use Google Analytics to analyse the use of our website.
14.2 Our analytics service provider generates statistical and other information about website use by means of cookies.
14.3 The analytics cookies used by our website have the following names: _ga, _gat, __utma, __utmt, __utmb, __utmc, __utmz and __utmv.
14.4 The information generated relating to our website is used to create reports about the use of our website.
15. Third party cookies
15.1 Our website does not currently use any third party cookies.
16. Blocking cookies
16.1 Most browsers allow you to refuse to accept cookies; for example:
(a) in Internet Explorer (version 11) you can block cookies using the cookie handling override settings available by clicking “Tools”, “Internet Options”, “Privacy” and then “Advanced”;
(b) in Firefox (version 39) you can block all cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history” from the drop-down menu, and unticking “Accept cookies from sites”; and
(c) in Chrome (version 44), you can block all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Content settings”, and then selecting “Block sites from setting any data” under the “Cookies” heading.
16.2 Blocking all cookies will have a negative impact upon the usability of many websites.
16.3 If you block cookies, you will not be able to use all the features on our website.
17. Deleting cookies
17.1 You can delete cookies already stored on your computer; for example:
(a) in Internet Explorer (version 11), you must manually delete cookie files (you can find instructions for doing so at http://windows.microsoft.com/en-gb/internet-explorer/delete-manage-cookies#ie=ie-11);
(b) in Firefox (version 39), you can delete cookies by clicking “Tools”, “Options” and “Privacy”, then selecting “Use custom settings for history” from the drop-down menu, clicking “Show Cookies”, and then clicking “Remove All Cookies”; and
(c) in Chrome (version 44), you can delete all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Clear browsing data”, and then selecting “Cookies and other site and plug-in data” before clicking “Clear browsing data”.
17.2 Deleting cookies will have a negative impact on the usability of many websites.
18. Data protection registration
18.1 We are registered as a data controller with the UK Information Commissioner’s Office.
18.2 Our data protection registration number is ZA175387.
19. Our details
19.1 This website is owned and operated by Brightwater Services Ltd.
19.2 We are registered in Scotland under registration number SC514287, and our registered office is 29 York Place, Edinburgh, EH1 3HP.
19.3 Our principal place of business is at Suite 7 – First Floor, Stuart House, Eskmills, Station Road, Musselburgh, EH21 7PB.
19.4 You can contact us by writing to the business address given above, by using our website contact form, by email to firstname.lastname@example.org or by telephone on 0330 022 05 70 / 0131 510 6909