Privacy Policy

About this Privacy Policy

Glasgow Community Energy is committed to protecting your personal information and being transparent about how we use it, whether you are a shareholder/member (or nominated representative), applying to become a shareholder/member (or nominated representative) or you have registered your details so you can hear more from us or are simply visiting our website.

This Privacy Policy aims to give you a clear explanation about how Glasgow Community Energy collects personal information (or “personal data”), the types of personal information we collect, how we use it (or “process” it), and whether we share it with anyone else. It also explains your legal rights and choices regarding the information you provide to us.

Children’s privacy: Our website and services are not aimed at children under the age of 16.

Our contact details

If you need to contact us about this Privacy Policy or have a question about your personal data, our contact details are:

Glasgow Community Energy
Flat 2
41 Lansdowne Crescent
Glasgow
G20 6NH

Email: info@glasgowenergy.coop

Who is responsible for your personal data?

Glasgow Community Energy is responsible for how and why your personal data is used. The legal phrase for this is Data Controller (or “Controller”).

Glasgow Community Energy is the trading name of the Radical Renewable Art & Activism Community Energy Society Ltd.

The Radical Renewable Art & Activism Community Energy Society Ltd is a Community Benefit Society registered with the Financial Conduct Authority (FCA) under the Co-operative & Community Benefit Societies Act 2014 (registration no. 7148).

Our registered address is:
Flat 2, 41 Lansdowne Crescent, Glasgow, G20 6NH

Our business address is:
Flat 2, 41 Lansdowne Crescent, Glasgow, G20 6NH

Your legal rights

You have the following legal rights in relation to the processing of your personal information:

• To be informed: You have the right to know what personal information we are processing about you, how and why. The information in this Privacy Policy is intended to provide you with this information. If you need more information, please ask us;
• Access: You have the right to request a copy of your personal information that we hold about you together with other information relating to its use, subject to the application of any relevant legal exemptions;
• Erasure: At your request, we will delete your personal information from our records providing we don’t have an overriding legitimate reason for holding on to it;
• Rectification: We aim to keep your personal information accurate, current, and complete. We encourage you to contact us by emailing info@glasgowenergy.coop to let us know if any of your personal information is inaccurate or changes, so that we can keep it correct and up-to-date;
• Objecting: In certain circumstances, you have the right to object to the processing of your personal information where we are: (i) processing your personal information on the legal basis of legitimate interests and we have no compelling reason we can demonstrate to continue with that processing, or (ii) using your personal information for direct marketing, or (iii) using your personal information for statistical purposes;
• Right to restrict processing: you have the right to ask us to restrict the processing of your personal information whilst a disagreement is resolved about its accuracy or whether we can use it on the legal basis of “legitimate interests”;
• Rights related to automated decision making: where we take automated decisions in relation to your personal information with no human involvement (i.e. such as credit scoring) you have the right to ask us for human intervention or to challenge any such decision;
• Right to withdraw consent: If you have provided your consent to the collection, processing and transfer of your personal information, you have the right to fully or partly withdraw your consent;
• Porting: You have the right to request that some of your personal information is provided to you, or to another information controller, in a commonly used, machine-readable format.

How to exercise your legal rights

You may exercise any of the above rights, at any time, by emailing: info@glasgowenergy.coop together with a proof of your identity, i.e. a copy of your ID card, or passport, or any other valid identifying document.

Complaints

If you believe that your information protection rights may have been breached, you have the right to lodge a complaint with the applicable supervisory authority, or to seek a remedy through the courts. The UK, supervisory body is the Information Commissioner’s Office (ICO).

Other websites and 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 policy of every website you visit.

Information about other people

If you provide information to us about any person other than yourself, such as your partner, you must ensure that they understand how their information will be used, and that they have given their permission for you to disclose it to us and for you to allow us, and our outsourced service providers, to use it.

How long we keep your personal data

Glasgow Community Energy 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 and, where required for us to assert or defend against legal claims, until the end of the relevant retention period or until the claims in question have been settled.

We do keep certain records, which may include personal data, for more extended periods, for example, after you have sold your shareholding, if we need to do this to comply with our legal, regulatory, tax or accounting needs and obligations.
For example:

• If you unsubscribe from our marketing database we would usually delete your personal data from our marketing database as soon as possible and at the latest within one month. In line with standard direct marketing good practice, your contact details only would be transferred to a suppression list to avoid accidentally sending you marketing in the future.
• If you have contacted us with a general enquiry via our website, we will reply to you using the contact details provided. Unless you have specifically consented to your personal data being added to our direct marketing database, your contact information will be stored for a period of up to one year in case any follow up is required.

Upon expiry of the applicable retention period we will securely destroy your personal data in accordance with applicable laws and regulations.

If you want to learn more about our specific retention periods for your personal data established in our retention policy, you may contact us at Glasgow Community Energy.

If you fail to provide personal data

Where we need to collect personal data by law or in order to process your instructions or perform a contract we have with you and you fail to provide that data when requested, we may not be able to carry out your instructions or perform the contract we have or are trying to enter into with you. In this case, we may have to cancel our engagement or contract you have with us, but we will notify you if this is the case at the time.

Updating your personal data

If any of the personal data that you have provided to us changes, for example if you change your email address or if you wish to cancel any request you have made of us, or if you become aware we have any inaccurate personal data about you, please let us know by sending an email to info@glasgowenergy.coop. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.

Automated decision making and profiling

Glasgow Community Energy does not use your personal information for automated decision making or profiling purposes.

Automated decision-making is the process of making a decision which produces significant legal effects for that individual and that decision is made solely by automated means without a human being involved at all.

Profiling means the analysis of certain characteristics of an individual’s personality, behaviour, interests and habits to find out more about their preferences or to make predictions about their behaviour and/ or to make decisions about them.

Change of ownership

If on the winding up or dissolution, we were to transfer Glasgow Community Energy’s assets to another similar organisation, your records would also transfer to the new organisation. Limited information may also be shared, where required, with legal and other professional advisors involved in that transfer.

The reason we would transfer your records is to minimise the disruption to the on-going operation of Glasgow Community Energy’s assets and to ensure we and a new owner were able to comply with our legal obligations regarding the retention of such records, including the ongoing delivery of care and service to you and our associates.

Changes to our Privacy Policy

We will update and change this Privacy Policy from time to time to reflect any changes to the way in which we process your personal information or changing legal requirements. Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Policy.

Want more detail?

If you are a shareholder/member of Glasgow Community Energy (including prospective and past shareholders or, where applicable, their nominated representatives) or a contact who is not a shareholders/member (for example, a subscriber to our Newsletter), the next part of the Privacy Policy tells you more about the personal data we collect in each instance, why and who we share it with.

If you are none of the above and are just visiting our website, this won’t apply to you, please just read our Cookie Policy below.

Personal Data we collect and how we use it

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 as follows:

• Identity and Contact Data: including your first name, surname, title, email address, postal address, telephone number, mobile number, date of birth;
• A record that you are an investor in one or more of our projects including the name of the project, amount of investment, number of shares, the reference number that we attribute to you when you become a shareholder, the votes you cast;
• Financial and Payment Data: including bank account name, bank account number, sort code and other data necessary for processing payments and fraud prevention;
• Representatives details: Proof of any changes to the details that we hold about you including details of any representatives such as a Power of Attorney or Executor;
• Your preferences in receiving marketing information from us including mode of communication;

In addition to the above, where you are a visitor to our website, we may collect any of the following:

• Profile and Usage Data: your preferences in receiving marketing information from us, preferred language, your communication preferences and information about how you use our website including the services/pages you viewed or searched for, page response times, download errors, length of visits, referring website/page and page interaction information (such as scrolling, clicks, and mouse-overs);
• Technical Data, including information collected during your visits to our website(s), the Internet Protocol (IP) address, login data, browser type and version, device type, time zone setting, browser plug-in types and versions, operating system and platform;
• Any other information you give us: such as information provided in an online enquiry form or email or other correspondence.

Special Categories of Personal Data

Special Category Personal Data specifically means personal data relating to 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.

Glasgow Community Energy does not expect to routinely collect or process special categories of personal data unless you give this information to us.

Neither do we routinely collect any information about criminal convictions (including offences and alleged offences and any court proceedings or sentence) unless you give this sort of information to us.

Source of your personal information

Glasgow Community Energy expects to collect your personal information directly from you and from third party sources. For example:

• Directly from you: when you contact us via our website or complete our online contact form or “Register Your Interest” form or share application form;
• Indirectly from third parties: where information is provided by third parties such as any nominated representative or agent of yours;
• Indirectly via our website: from connection data sent to our webserver by your browser when you connect to Glasgow Community Energy;
• Indirectly via web-based services: for example, where analytical information is collected through electronic platforms made available to you in connection with services that we provide to you.

How will we use your personal information?

We use your personal information (with the support of Energy4All, our main service provider):

• to administer, process and manage your communications (including your online enquiry) and our relationship;
• to manage your shareholding;
• to keep our shareholder register up-to-date and to comply with our various legal obligations;
• to notify you of shareholder related information, including important information about dividend distributions, shareholder resolutions, reports and meetings, including details of our Annual General Meeting;
• to send you relevant information relating to Glasgow Community Energy project updates and details of any events in our Newsletter.
• to process payments;
• We use the logs from our servers to assist in our security, as well as to develop our online strategy. For example, where they have not been disabled, our cookies may be used to improve the user-friendliness of our website, enhance your experience using our website and help us work out which pages are most popular.

Legal Basis for processing your personal data

The UK General Data Protection Regulation (GDPR) requires us to provide you with information about the legal reason (or “legal basis”) for processing your personal data.

Legal Obligation:

We may need to use your personal data in order to comply with our legal obligations. For example:

• If you opt-out of receiving our marketing information, we will delete your personal information except for your basic contact information which will be transferred into a secure separate list known as a direct marketing suppression list, to ensure that we comply with your objection to direct marketing. The legal basis for retaining your basic contact details is that it is necessary to do so in order to comply with our legal obligation under data protection law.
• To comply with our various statutory obligations and your rights as a shareholder in accordance with our Articles of Association and any applicable laws including notifying you of meetings where you have a right to vote such as the Annual General Meeting. We will also process your personal data to notify you of any dividends or interest payments that are due to be paid to you.
• To maintain a record of your investment so that we can comply with anti-money laundering and tax laws.

Contract:

If you enter into a contract with Glasgow Community Energy, we will need to collect and process some personal information in order to administer that contract. Where this happens, our legal basis for processing your personal information is contractual.

Legitimate Interests:

In most other cases, our use of your personal data will be on the legal basis that it is necessary for our legitimate interests, or those of a trusted third party such as Energy4All (Energy4All is our community energy partner), providing those interests are not overridden by your own interests or fundamental rights and freedoms. For example:

• We will need to process your personal information in order to respond to and administer your enquiry or correspondence;
• To keep you informed about important information, developments and updates;
• We may process your personal information for security purposes or to develop our business generally;

Consent:

Where you have provided your consent we may process your personal information in the following circumstances:

• to publish a testimonial, you have provided in conjunction with your name;
• to publish an image or video of you where you are the main focus (or your image is accompanied by your name), on our website or on a third-party social networking platform such as LinkedIn, Facebook or Twitter;
• to share your personal data with any third party for marketing purposes. For example, we may share your information with Energy4All but only with your specific consent.

Direct Marketing

Glasgow Community Energy processes personal data for the purposes of direct marketing and promoting our organisation. However, unless you consent, we will never sell or rent your personal information to a third party, for that third party’s marketing purposes.

You can stop receiving our marketing at any time by clicking on the “unsubscribe” option in our email communications or by emailing: info@glasgowenergy.coop
Where we require your consent to send you direct marketing, you have the legal right to withdraw that consent at any time.

Withdrawal of consent to receive marketing communications will not affect the processing of your personal data for the provision of our other services which do not rely upon your consent. For example, if you are an investor in any of our projects and withdraw your marketing consent, you will continue to be sent only communications which relate directly to the operation of the project(s) in which you invested.

However, by withdrawing or not providing your consent to direct marketing, you may not receive information about Glasgow Community Energy project updates and details of any events in our Newsletter.

Explicit Consent and Substantial Public Interests Based Upon Law

Rarely, Glasgow Community Energy needs to process special categories of personal data such as health or medical information. For example, in order that we can cater for specific dietary needs or a hearing impairment at an event you are attending. We will only process this sort of information with your explicit consent or where it is necessary for reasons of substantial public interest that are based upon a law.

Legal Claims

Glasgow Community Energy may process special category personal information where it is necessary to establish, exercise or defence legal claims or where a court is acting in a judicial capacity.

How we share your personal data

Normally, we wouldn’t expect to share your personal data with another organisation except in the following circumstances:

• with trusted affiliates or undertakings for the purposes of providing you with our services as described in this Privacy Policy, for example Energy4All.
• on a confidential basis with third parties for the purposes of collecting your feedback on our services, to help us measure our performance and to improve and promote our services;
• with trusted service providers who we engage. For example, external software providers for managing payments to our shareholders/members and sending Newsletters. Where we do this, the service providers are contractually required by us to keep your personal data secure and to only process it strictly in accordance with our instructions and in accordance with data protection laws;
• where you have consented, with third parties for their marketing purposes;
• with third party data controllers where we have a legal obligation to do so including regulators who regulate how we operate such as HMRC, Companies House, Financial Conduct Authority and the Information Commissioner’s Office;
• with any individual or company to whom we propose to transfer our obligations and rights in relation to the administration of our share register;
• with any third-party at your request or with your specific consent. For example, with your agent or other representative;
• with any third-party where if the law requires or permits disclosure, or there is a duty to the public to share or disclose your personal information. For example, for the purpose of verifying shareholdings or contacting shareholders about matters relating to the company, their shareholding or a related exercise of rights;
• Working with regulators and fraud prevention and detection agencies:
• We may use your personal information to help us to detect and prevent fraud, fight financial crime and meet our regulatory responsibilities. This may involve checking public registers (e.g. the electoral roll or registers of county court judgments, bankruptcy orders or repossessions), conducting online searches from websites and other information sharing platforms and using databases managed by credit reference agencies and other reputable organisations. This will help us verify your identity and carry out tracing exercises. We may also share your information and undertake searches with third party organisations such as public bodies, credit reference agencies, fraud prevention agencies and our regulators (which include the FCA, and ICO). If you provide us with false or inaccurate information and we suspect fraud, we will record this to prevent further fraud and money laundering.

Information we transfer outside the European Economic Area (EEA)

We do not transfer your personal data outside the UK.

Cookies and similar technologies

Just like many other websites, our website uses some standard technology to store and manage user preferences.

For example, to allow shareholders and members to log into the secure member area of our website. These are necessary for security purposes, to enable content, and gather analytic and usage data. For example, we use Google Analytics, a service of Google Inc. to track the usage of our website. As a consequence, if you allow your web browser to accept cookies from Google Analytics or accept third-party cookies while browsing our website, data provided automatically by your web browser will be transmitted to and stored on Google’s servers.

We do not use cookies to deliver targeted advertising.

By using our website, you agree that we can use cookies for the purposes described in our Cookie Policy unless you adjust your browser to manage or prevent cookies.

How Glasgow Community Energy uses Cookies

What are cookies?

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. Unless you have adjusted your browser setting so that it will refuse cookies, our system will send your device a cookie when you visit our web site.

The cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

Controlling and deleting cookies

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. This may prevent you from taking full advantage of our website.

The websites allaboutcookies.org and aboutcookies.org contain comprehensive information about cookies including how to see what cookies have been set and how to manage and delete them.

Security of your personal data

Glasgow Community Energy has put in place appropriate technical and organisational security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

For example, your personal data is held in a secure password-protected database accessible only by those staff or IT service providers that need access. Where it is necessary to do so, some of your data may be downloaded and stored on paper at our office while we carry out analysis of data. Paper based data is securely shredded and disposed of at the end of any analysis work.

If you would like more specific information about our security measures please contact us at info@glasgowenergy.coop