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Privacy Statement (GDPR)

Vayu Limited (Vayu) takes your privacy very seriously and is committed to protecting your personal data.  The following privacy information is being provided to you as outlined in the General Data Protection Regulation (EU) 2016/679 (the “GDPR”).

In this Privacy Policy (the “Policy”), we explain how we collect personal information about you, how we use it and how you can interact with us about it. We try to keep this Policy as simple as possible but if you are unfamiliar with our terms, or want more detail on any of the information here, you can contact us at dataprotection@vayu.ie or you can also ask for more details by calling +3531 8849400.

Under this Policy, and unless we have entered into a different agreement with you, we will be what’s known under the GDPR as the “controller” of the personal data you provide to us.

Who we are

When we talk about “Vayu”, or “us” or “we” in this notice, we are talking about Vayu Limited.  We share your information within Vayu only, to help us provide our services, comply with regulatory and legal requirements, and improve our products.

  1. Data Protection Department

Our Data Protection Department oversees how we collect, use, share and protect your information to ensure your rights are fulfilled. You can contact us at dataprotection@vayu.ie.

  1. How we collect information about you

We collect personal information from you, for example when we set up a new customer account. We also collect information through our website, via emails, social media, discussion forums, market research, and our CCTV footage when visiting our office.  We also record phone conversations. 

Our website and MyVayu use ‘cookie’ technology.  A cookie is a little piece of text that our server places on your device when you visit Vayu’s website and MyVayu sites.  They help us make the sites work better for you.

  1. The information we collect about you

Your Data. This is information about you that you give us by filling in forms on our Site or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you use our Site, or the Services, or report a problem with our Site.

The information you give us may include:

  • Identity Data: your full name, address, e-mail address, phone number, address and title.
  • Financial Data: your financial including bank account details, billing contact email address and VAT number.

Information we collect about you.

With regard to each of your visits to our Site we will automatically collect the following information:

  • Technical Data: technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, how often you use the application and other performance data; and
  • Usage Data: information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call us. 

No special categories of personal data. 

We do not require or collect any personal data that is your sensitive personal data or any special category of personal data under the GDPR, unless you decide to provide this information to us.

  1. How we keep your information safe

We protect your information with security measures under the laws that apply and we meet international and energy standards. We keep our computers, files and buildings secure. When you contact us to ask about your information, we may ask you to identify yourself. This is to help protect your information.

  1. How long we keep your information

To meet our legal and regulatory obligations, we hold your information while you are a customer, employee or jobseeker and for an appropriate period thereafter.  We do not hold it for longer than necessary.

Meeting our legal and regulatory obligations to use your information lawfully, we rely on one or more of the following legal bases:

  • legal obligation;
  • protecting the vital interests of you or others;
  • your legitimate interests; and
  • your consent.

This is described more in the table shown below.

To meet our regulatory and legal obligations, we collect some of your personal information, verify it, keep it up to date through regular checks, and delete it once we no longer have to keep it. If you do not provide the information we need, or help us keep it up to date, we may not be able to provide you with our energy reports, products and services.

  1. Consent

With direct marketing, for example market reports for you to get the latest prices from the energy market we need your consent, to make you aware of market changes and new products and services which may be of interest to you.

We may do this by phone, post, email, text or through other digital media.  You can decide if you want to receive direct marketing by opting ‘out’ or ‘in’ when you receive communications about new products and services. Where you have given us your consent to send marketing communications to you, you will always have the right to withdraw your consent at any time. If we ever contact you to get your feedback on ways to improve our products and services, you have the choice to opt out.

You have the right to object to the processing of your personal data for our marketing purposes. To object or if you change your mind at any later time, you can withdraw your consent to the processing of your personal data for such marketing purposes by contacting us at dataprotection@vayu.ie.

You may also opt out of receiving marketing communications at any time by selecting the unsubscribe option when you receive an electronic marketing communication from us. The withdrawal of your consent will not impact upon the lawfulness of processing based on your consent prior to the withdrawal.

  1. How we use your information

We will only use your personal information 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 interest (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.

We have set out below, in table format, a description of the ways we plan to use your personal data and the legal basis we rely only to do so.

We have also identified our legitimate interests where appropriate:

Purpose/Activity

Type of data

Legal basis for processing

To respond to your queries and to provide you with the information you request from us in relation to our products or Services.

–  Identity Data

–  Technical Data

–  Usage Data

 

–  Necessary for our legitimate interests (to respond to new or existing customer queries and grow our business)

–  Performance of a contact with you

To manage payments, fees and charges and to collect and recover money owed to us.

–  Identity Data

–  Financial Data

–    Performance of a contract with you

–    Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you, including notifying you about changes to the Services, or our Privacy Policy.

–  Identity Data

–  Technical Data

–  Usage Data

 

 

–    Performance of a contract

–    Necessary to comply with a legal obligation

–    Necessary for our legitimate interests (to keep our records updated and to study how customers use our products and services).

To provide you with information about services we offer that are similar to those that you have enquired about.

–  Identity Data

–  Technical Data

–  Usage Data

Necessary for our legitimate interests (to develop our products or Services and grow our business)

Where you have given us your consent to do so, to provide you with information about other services we feel may interest you.

–  Identity Data

–  Technical Data

–  Usage Data

Consent

To ensure that content is presented in the most effective manner for you and for your computer or device.

–  Identity Data

–  Technical Data

–  Usage Data

Necessary for our legitimate interests (to keep our Site and the Services updated and relevant and to develop and grow our business).

To administer and protect our business, our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.

–  Identity Data

–  Technical Data

–  Usage Data

Necessary for our legitimate interests (for running our business and as part of our efforts to keep our Site and the Services safe and secure)

To use data analytics to improve or optimise our Site, marketing, customer relationships and experiences.

–  Technical Data

–  Usage Data

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Site and the Services updated and relevant, to develop and grow our business and inform our marketing strategy).

To measure or understand the effectiveness of advertising we serve to you and others, and, where applicable, to deliver relevant advertising to you.

–  Identify Data

–  Technical Data

–  Usage Data

Necessary for our legitimate interests (to study how customers use our products or Services, to develop them, to grow our business and to inform our marketing strategy).

 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at dataprotection@vayu.ie.

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 this Policy, where this is required or permitted by law.

  1. Your information and third parties

In the interest of managing you energy we may on occasion pass your details to third parties e.g. SEAI, Energy Efficiency Auditor but we would not forward this without your prior consent. We may also share your name, address and mobile number when we are delivering a direct marketing item or if we carry out some market research with a reputable market research company.

You can exercise your rights by contacting us at +3531 8849400, using our social media channels or by visiting our website at www.vayu.ie/data-protection.

  1. International Transfers

Personal Data may be transferred to our trusted partners and service providers who maintain their servers outside of the European Economic Area (“EEA”), where the privacy and data protection laws may not be as protective as those in your jurisdiction. This is only for the purposes of providing, and to the extent necessary to provide, the Services to you. There are special requirements set out under Chapter V of the GDPR (with which we would comply) to regulate such data transfers and ensure that adequate security measures are in place to safeguard and maintain the integrity of your personal data on transfer.

For more information about this and the safeguards in place relating to the transfer, please contact us by email at dataprotection@vayu.ie.

  1. Third Party Material

We always endeavour to deal with vendors and other third parties who are GDPR compliant or, in the case of the third parties located outside of the EEA, who are certified as compliant with the EU-US Privacy Shield, as applicable, or who have adequate security measures in place to safeguard the security of personal data. That said, we, our employees, agents, holding company and subsidiaries, accept no liability howsoever arising for the content or reliability of any third party materials or websites referenced by hyperlink or other means on the Site or for the data collection and use practices or security measures used by such third parties. If you submit personal data to any of those sites, your personal data is governed by their privacy policy.

We encourage you to carefully read their privacy policies.

  1. We can help you with

Accessing your personal information: You can ask us for a copy of the personal information we hold. You can ask us about how we collect, share and use your personal information. Updating and correcting your personal details. Removing consent: You can change your mind wherever you give us your consent, such as for direct marketing, you may have the right to restrict or object to us using your personal information.

Deleting your information (your right to be forgotten). You may ask us to delete your personal information. Moving your information (your right to Portability).

Where possible we can share a digital copy of your information directly with you or another organisation. When you contact us to ask about your information, we may ask you to identify yourself. This is to help protect your information.

You have the right to be informed if your personal data will be subject to automated decision making, including profiling. You also have the right not to be subject to a decision based solely on automated process, including profiling, where that decision impacts on your legal rights. There are some exceptions to this rule, where, for example, the decision is necessary in connection with the performance of a contract between us, is authorised by law or where you have given your explicit consent to this automated processing.

Making a complaint 

If you have a complaint about the use of your personal information, please let a member of staff in Vayu know, and / or our Data Protection Department dataprotection@vayu.ie giving them the opportunity to put things right as quickly as possible. If you wish to make a complaint you may do so in person, by telephone, in writing and by email. Please be assured that all complaints received will be fully investigated. You can register by phone or by email.

We ask that you supply as much information as possible to help resolve your complaint quickly.

You can also contact the Data Protection Commission in Ireland at www.dataprotection.ie.

  1. Data Breach Policy

Vayu is committed to protecting the confidentiality of the data we process. In the event of a data breach that could “result in a risk for the rights and freedoms of individuals”, Vayu will report the breach to the Supervisory Authority within 72 hours of becoming aware of the breach. Vayu will also notify the Data Subject of the breach without undue delay.

The details contained within the notification shall be in accordance with General Data Protection Regulation (GDPR) (EU) 2016/679 Art. 33(3).

  1. Updates to this notice

We will make changes to this Policy from time to time, particularly when we change how we use your information, and change our technology and products.  You can always find the latest version of this Policy on our website at www.vayu.ie/data-protection.