Netro Energy Limited
Ground Floor, Ibis House
Ibis Court, Centre Park
Warrington WA1 1RL
Important information and who we are:
We have appointed a data protection officer (“DPO”) who is responsible for overseeing this policy. If you have any questions about this policy please use our contact form and the DPO will be sent your enquiry.
The data we collect
We may collect, use, store and transfer different kinds of personal data about you when you make contact with us via our website, by call, email or letter, when you become a client or use any of our services, which we have grouped together as follows:
- Identity Data: includes first name, last name.
- Contact Data includes postal or email address and telephone numbers.
- 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.
- Usage Data includes information about how you use our website, products and services.
We also collect, use and share aggregated data such as statistical or demographic data. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will 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.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
This website is not intended for children and we do not knowingly collect data relating to children.
How is your personal data collected
We use different methods to collect data from about you including through:
- Direct interactions. You may give us your Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise.
Technical Data is also collected from the following parties:
(a) analytics providers such as Google based outside the UK;
(b) networks based inside OR outside the UK; and
(c) search information providers based inside OR outside the UK.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
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 it is necessary for the administrative running of our business (see more detail below), or
- Where we need to comply with a legal obligation.
Purposes for which we will use your personal data
Purpose / Activity:
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of data:
- (a) Identity
- (b) Contact
- (c) Technical
Lawful basis for processing including basis of legitimate interest:
- (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
- (b) Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Type of data:
- (a) Technical
- (b) Usage
Lawful basis for processing including basis of legitimate interest:
- Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the details above.
Internal Third Parties – Other companies in the Netro Energy Group acting as joint controllers or processors and who are based in and outside of the UK and provide system administration services and undertake leadership reporting.
External Third Parties
- Third party providers of administrative functions necessary to the functionality of our business, such as IT services, website technical support and other advisory services.
- Our affiliated company and group, Capital Dynamics are a global group and therefore we may store your personal data in any location globally and we may share your personal data with our service providers and/or relevant regulators and this may involve transferring it to countries inside and outside the European Economic Area (EEA).
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.
Whenever we transfer your personal data out of the UK, we 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 by the European Commission 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.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
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.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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 achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances we will 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
Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to discuss or exercise any of your legal rights which vary according to where you live, please contact us and our DPO will be in touch.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
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.
We try to respond to all legitimate requests within one month. Occasionally it could 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.