Website, IHD and app privacy notice
The full name of our company is Green Energy Options Limited (“geo”, “we”, “us” or “our”). geo is registered in England & Wales under registration number 5783558. Our registered address is 3 St Mary’s Court, Main Street, Hardwick, Cambridge, CB23 7QS. You can contact us by writing to our Data Protection Officer at our registered address or by email at dpo@geotogether.com.
This Privacy Notice sets out how geo uses, processes and protects any information that you provide or data that is collected when you use the geo website, a geo In-Home Display product (the “IHD”) and/or a geo App (whether this is the heating app accessed via your phone or via the app website) (together the “Services”). geo is committed to ensuring that your privacy is protected. Should you be asked to provide certain information by which you can be identified (or other “personal data” as defined in the UK Data Protection Act 2018 and/or the UK GDPR) when using the Services, you can be assured that it will only be used as outlined in this Privacy Notice.
This policy may change from time to time. You should check this policy for updates or when notified to ensure that you understand and are happy with any changes. By using or continuing to use the Services, you agree to this policy as in force at the time of that use.
1. Purpose of this privacy notice
This Privacy Notice explains our approach to any personal data that we might collect from you and the purposes for which we process your personal data. This Privacy Notice also sets out your rights in respect of our processing of your personal data.
When we talk about “personal data”, we mean any information which relates to an identified or identifiable living individual. An individual is ‘identified’ or ‘identifiable’ if they can be distinguished from other individuals.
Your Account Data (which we fully define below in What Personal Data We Collect) that you may enter using the App may include your name and contact details and would fall within the definition of personal data. Your Energy Use Data (which we also fully define below in What Personal Data We Collect) collected through the IHD will also fall within the definition of personal data – even though Energy Use Data, on its own, may not include any ‘real world’ identifiers (like your name and contact details).
This Privacy Notice is intended to assist you in making informed decisions when using our Services. Please take a moment to read and understand it.
This Privacy Notice only applies to the use of your personal data obtained by us directly. It does not apply to personal data collected by third parties during your communications with those third parties or your use of their products or services (for example, where your IHD has been provided by your energy supplier and they have collected additional information as part of that process).
2. How to contact us
If you have any questions about this Privacy Notice or want to exercise your rights as a data subject set out in this Privacy Notice, you can contact us using the following methods:
| On Site | Contact us using our enquiry form on our website. |
| Send us an email at: dpo@geotogether.com | |
| Post | Write to us at: The Data Protection Officer, geo, 3 St. Mary’s Court, Main Street, Hardwick, Cambridge, CB23 7QS |
3. What personal data we collect
In providing our Services, we may collect and process different types of personal data about you for different processing purposes. The types of personal data we collect depends on who you are and how you use the Services and includes the following:
| Account Data | Account username; email address; password; purchase/order details; home address; contact preferences; information added by a user via their account (e.g. the number of bedrooms in the applicable property, how you heat your home, how many people live in your home). |
| Hardware Data | The device type that our geo App is installed on (e.g. device identification numbers, type of device).
We also collect device related data in order to support the device and it’s services. This can include MAC address, IP Address, Timezone, Make or Model. |
| Usage Data | We collect information on how you interact with our services, including: The duration of your usage; The pages you open and frequent; The time you spend on each page; Your exit points from the website or app; Your navigation journey through the website or app; How you arrived at the website or app; The pages you view; Your actions on specific pages or within the app (such as links you click on); Whether you access the website or app via a mobile device or laptop; Your web browser type; Demographic information (e.g., age range and gender); Usage patterns within the app, including time spent, interactions, and navigational pathways. |
| Geo Device Data | Smart meter data including: gas consumption (in m3 and/or kWh, conversion factor and cost); Electricity consumption and export (in kWh and cost); Tariffs for energy; Sensor data (e.g. temperature and humidity) (if the system is equipped with these sensors); MPAN (Meter Point Administration Number); MPRN (Meter Point Reference Number); Schedules for specific energy appliances (e.g. heating or EV charging schedules, when a heating system or EV charger is paired with the relevant geo system); Live Power reading (in watts); Pre-payment information if applicable (electricity &/or gas credit /debt / balance); Carbon (kg) from gas energy usage (if supported by meter);
Where you have opted to receive the ‘Home Energy Insights’ service from geo and you have provided your consent to obtain this service, the energy consumption data listed above will be provided to geo from your Smart Meter on a half hourly basis. |
| Location Data | Address, Postcode and/or Lat+Long if applicable to the service you have requested. |
| Purchase Data (when you buy a product or service from our Website) | Name; telephone number; purchase/order details (what you are buying); home address; contact preferences; email address; shipment address; billing address. |
| Enquiry Data (including any enquiry form data and chat data) | Name; email address; customer narrative submitted via online forms; online chat history. |
| Payment Data | Your billing information, transaction and payment card or other payment method information, bank account and payment details; Billing address; |
4. How we collect and receive personal data
We collect and receive personal data using different methods:
| Personal data you provide to us | We will collect the information directly from you, e.g. when you enter information into the Website or your IHD and the App and when the Services are functioning and gathering your energy data. We may also capture data from your geo Thermostat if you have one. This may occur when you change your target temperature or when you direct a change of mode.
We also collect information when you are browsing the Website (please see our Cookies policy for more information). |
| Personal data received from third parties | We may receive personal data about you from third parties. Such third parties may include your energy supplier and third parties that provide technical services to us so that we can provide our Services.
Where you use the ‘Home Energy Insights’ service, we will receive your data using a service provided by N3rgy Limited. Geo will use this service to interface with the national smart meter systems in order to collect, store and manage your Smart Meter data. This service uses the Smart Energy Code Party credentials and Party ID: N3rgy Limited, company number 11203504, or 4 Ovington Drive, Fleet, GU51 1DF, UK.
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| Freshdesk customer support portal | We will use the information supplied by you into our customer support portal to help us resolve your product support query. |
5. Who we collect personal data about
We collect and process personal data from the following people:
| Customers and Users | If you buy or use our Services, we may collect and process your personal data in connection with the supply of goods or services to you. |
6. How we use your personal data
We use your personal data for the purposes set out in this section. If we wish to make any changes to these purposes, or if we wish to use your personal data for any purpose that is not listed in this section, we will notify you using the contact details we hold for you:
| Register and access your account | Personal data used: Account Data, Hardware Data, Location Data;
Explanation: You will register your details with geo in order to gain access to certain features and functionality on the App and the IHD. We will use the information you provide to identify you when you log in to your account; so that we can administer and contact you about your account; so that we can link your system to your contact details and provide the most appropriate services to you. |
| To provide you with and/or show your energy consumption data and other energy related data on or via your device | Personal data used: Geo Device Data
Explanation: We may display this information on your IHD or via your app. This data may be correlated with input data that you have given, such as your energy tariff information or home temperature. We may provide this information so that you can see how much energy you are using, what it may be costing you and how you can manage your energy usage (e.g. energy saving tips). Analysing data to provide energy insights such as the amount of energy consumed by different appliances in the home. This may also include disaggregation of data which is the breakdown of your energy consumption data so that it can be made available to you in various forms. |
| Develop our products | Personal data used: Account Data, Hardware Data, Usage Data, Geo Device Data, Location Data
Explanation: We use this information to help us to monitor and improve our Services, to assist with the selection of future service lines and to train our personnel. |
| Develop our Services and make the App services better for our customers | Personal data used: Account Data, Mobile Device Data, Usage Data
Explanation: We will also use the information to understand how you use our App so that we can improve it. |
| Answer your enquiries | Personal data used: Account Data, Hardware Data, Location Data
Explanation: When you make an enquiry, we will collect this information, as well as any other personal data you volunteer, to enable us to respond to your enquiry. |
| To manage our relationship with you including notifying you of changes to the App or any Services | Personal data used: Account Data
Explanation: We may use your personal data to inform you of any changes to our Services |
| Comply with our legal obligations and assist with the administration of our business | Personal data used: Account Data, Hardware Data, Usage Data, Geo Device Data, Location Data
Explanation: We may use your personal data: (i) to comply with our legal obligations; (ii) to enforce our legal rights; (iii) to protect the rights of third parties; and (iv) in connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of any of our assets. |
| So that we can communicate with your smart meter in order to provide you with the Services | Personal data used: Account Data
Explanation: We need to be able to communicate with your smart meter so that we can provide you with your energy information such as consumption information – in order to do this, the geo devices will use your address to establish the smart meter link. |
| To provide you with our goods and services when you make a purchase | Personal data used: Purchase Data; Payment Data.
Explanation: In order to make a purchase via the Website, we will need to obtain personal data from so that we can take payment and send the goods to you and / or provide you with the services that you have requested; |
| Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive or to check our website is working as intended | Personal data used: Usage data;
Explanation: Your consent as gathered with reference to our ‘Cookies policy’ available on our website. |
| Marketing our services to customers who have enquired about our products or services as well as existing and former customers | Personal data used: Enquiry Data; Purchase Data.
Explanation: For our legitimate interests, i.e. to promote our business to newly enquiring, existing and former customers, to promote product trials and new products. |
| Customer support portal | Personal data used: Enquiry data
Explanation: Customers who email us requesting support for their geo products, we will use the data provided in their email to provide support for their query. |
7. Our legal basis for processing your data
We will use your personal data where it is necessary for us to do so to perform our obligations in accordance with a relevant contract to which you are a party. This may be a contract that we have entered into with you or a contract that your energy supplier has entered into with you.
We will use your personal data where it is in our legitimate interest to do so. For example, to ensure that we provide access to the App and our Services in a secure and effective way and so that we can make improvements to our Services to best meet your needs. Or, for example, in connection with business transitions, to enforce our legal rights or to protect the rights of third parties.
We will use your personal data where it is necessary for us to do so to comply with any legal obligations imposed upon us, such as a court order or specific regulatory rules.
We will use your personal data to send you updates (by email, text message, telephone or post) about our products and/or services, including exclusive offers, promotions or new products.
We have a legitimate interest in using your personal data for marketing purposes. This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by using the ‘unsubscribe’ link in our emails.
Home Energy Insights Service Users
To access the Home Energy Insights service, you will have provided your consent to geo so that we can process the data concerned. This consent relates to geo’s processing of data that is produced by your Smart Meter so that we can provide the Home Energy Insights service to you. The data concerned is listed above in the section entitled “What Personal Data We Collect”. We will not share this data with any third party, and it will be held in accordance with the standards set out in this privacy policy. The data will only be used for the purposes of providing the service that you have chosen.
Your consent will be valid for 2 years (24 months), after which you will be asked to reconsent.
Your consent to this processing can be withdrawn at any time by contacting our customer services team at: customerservices@geotogether.com.
If you withdraw your consent, we will not be able to continue to provide the ‘Home Energy Insights’ service to you.
8. Sharing personal data
We only share personal data with others when we are legally permitted to do so. When we share personal data with others, we put contractual arrangements and security mechanisms in place to protect the personal data shared and to comply with our data protection, confidentiality and security standards and obligations.
When processing your personal data, we may need to share it with third parties as set out in the table below. This list is non-exhaustive and there may be circumstances where we need to share personal data with other third parties.
| Payment service providers, warehouses and delivery companies | We may share your personal data with payment providers who help deliver our products and/or services to you, e.g. payment service providers for purchases made via the Website, warehouses and delivery companies, our banks |
| Third-party suppliers who provide applications/ functionality, data processing or IT services | We share personal data with third parties who support us in providing our Services and help provide, run and manage our internal IT systems. Such third parties may also include, for example, providers of information technology, cloud-based software-as-a-service providers, identity management, hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them. We also share your personal data with third-party service providers to assist us with insight analytics and research. |
| Energy companies | We may share personal data with your energy supplier where you have a contract with them for the supply of your home energy. We may also share your data with the National Grid so that we can inform you of the best times to use your energy in a cost-efficient way – this forms part of the Services we will provide to you. |
| Auditors, lawyers, accountants and other professional advisers | We share personal data with professional services firms who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we may become involved in. |
| Law enforcement or other government and regulatory agencies and bodies | We share personal data with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation. |
| Another corporate entity in connection with a business transition | If we are involved in a business transition such as a merger, reorganisation, acquisition by another company, or sale of any of our assets, we may share or transfer personal data 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 Notice. |
| Other third parties | Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation. |
9. Transfers outside the UK and the European Economic Area ("EEA")
We may transfer, store and process your personal data outside the UK. Where we do so, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
10. How long we keep your personal data
In respect of personal data that we process in connection with the supply of our Services, we may retain your personal data for as long as you are a customer with us and in compliance with our data protection obligations. We may then destroy such files without further notice or liability.
Where we process personal data in connection with the registration and use of an account on our App or IHD, we may retain your personal data while your account is active and for up to 30 days from the date that the relevant account is terminated (and in compliance with our data protection obligations). We may then destroy such files without further notice or liability.
Where you have provided your consent to us processing your data, we will only process your data for so long as your consent is valid and where you have not withdrawn your consent. If you withdraw your consent, we will delete your data as soon as practicable and within 30 days of your request.
11. Confidentially and security of your personal data
We are committed to keeping the personal data you provide to us securely and we have implemented information security policies, rules and technical measures to protect the personal data under our control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. In addition, all our employees and data processors (i.e. those who process your personal data on our behalf) are obliged to respect the confidentiality of the personal data of all users of our Services.
12. Personal data of minors
Our Services are not intended for use by, or targeted at, minors (individuals under the age of 18) and we do not knowingly collect personal data of minors. However, this does not prevent minors from providing personal data to us. If we do collect personal data of minors, we will comply with all applicable laws and regulations relating to the processing of personal data of minors.
If you are under the age of 18, you must not use our App or purchase Services from us and you must not provide us with any personal information. If we discover that we are holding the personal data of a minor, we will delete that information as soon as possible. Please contact us if you have reason to believe that a minor may have submitted personal data to us (see the “How to contact us” section above).
13. Your rights as a data subject
You have certain rights in relation to the personal data we hold about you. These rights include the right: (i) to obtain copies of your personal data; (ii) to have your personal data corrected or deleted; (iii) to limit the way in which your personal data is used; (iv) to object to our use of your personal data; (v) to transfer your personal data; (vi) not to be subject to decisions based on automated processing (including profiling); and (vii) to complain to a supervisory authority.
If you would like to exercise any of these rights, please contact us using the details set out in the “How to Contact Us” section above.
| Your right of access | If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data (along with certain other details). If you require additional copies, we may charge a reasonable fee for producing those additional copies. |
| Your right to rectification | If the personal data we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal data with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we’ve shared your personal data with so that you can contact them. |
| Your right to erasure | You can ask us to delete or remove your personal data in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). If we have shared your personal data with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with so that you can contact them directly. |
| Your right to restrict processing | You can ask us to “block” or suppress the processing of your personal data in certain circumstances such as where you contest the accuracy of that personal data or you object to us processing it for a particular purpose. This may not mean that we will stop storing your personal data but, where we do keep it, we will tell you if we remove any restriction that we have placed on your personal data to stop us processing it further. If we’ve shared your personal data with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly. |
| Your right to data portability | You have the right, in certain circumstances, to obtain personal data you have provided to us (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or to ask us to transfer it to your chosen third party. |
| Your right to object | You can ask us to stop processing your personal data, and we will do so, if we are: (i) relying on our own or someone else’s legitimate interest to process your personal data, except if we can demonstrate compelling legal grounds for the processing; or (ii) processing your personal data for direct marketing purposes. |
| Your rights in relation to automated decision-making and profiling | You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us. |
| Your right to withdraw consent | If we rely on your consent (or explicit consent) as our legal basis for processing your personal data, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us using our contact details in the “How to Contact Us” section above or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email. |
| Your right to lodge a complaint with the supervisory authority | If you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, please contact us using the contact details provided in the “How to Contact Us” section above. You can also report any issues or complaints to the Information Commissioner’s Office (“ICO”). Contact details for the ICO can be found on its website at https://ico.org.uk. |
Last reviewed: 24th October 2024
