Privacy Policy

Your information will be processed and controlled by Tula Group Limited, its subsidiaries and trading styles (Group), which include Tula Energy Limited and Tula Communications.

For any additional information regarding this privacy policy you can contact us using the details below:

Address: Data Controller, Tula Group Limited, 82A James Carter Road, Mildenhall, Suffolk IP28 7DE

Phone: 0330 333 4900

Email: [email protected]

If you are dissatisfied with how your personal information has been used, you can contact us using the details above and we will respond after we have investigated your query. If you are still unhappy with the outcome of the complaint, you have the right to complain to the Information Commissioner’s Office by clicking on the following link: https://ico.org.uk/make-a-complaint/

This privacy notice explains how the Group promises to protect and use your personal information. This includes anything you may have told us yourself, information we may learn during the course of your contracts with us, data obtained from other parties, and your marketing preferences. This privacy notice also outlines your rights and how the law affects you.

We undertake to:

• Keep your data safe and secure.

• Allow you to manage your marketing preferences with us.

1. Information we may collect from you

During the course of our relationship with you, we may need to collect and process data about you. The types of data that we will require will fall broadly into one of the categories below:

Type of Personal Information

Contact

Financial

Public

Permission

Documentation

Technical Data

Analytics

Product/Service Specific

Description

Name, telephone, address, email address and how to contact you.

Bank details, credit information, personal financial status relating to company directors and proprietors.

Details from the electoral register, companies house, and other information publicly available about you or your business.

Permissions you have granted us to use your data, primarily for marketing purposes.

Data stored in documents you have sent us, such as bills and contracts from suppliers to enable us to help you switch, or leases to prove change of tenancy where required.

The types of equipment and software, IP addresses, geographical location, operating system and browser type you use to access our online services where available.

Data that tells us how you have nevigated across our websites, selected certain preferences on our website, what numberyou called us on, how long you called us for and the reason for the call etc.

Details about the products and services you havetaken, current suppliers, rates and preferences.

We will collect this data during the course of business by one of the following methods:

• When you complete forms on our sites or our partner’s sites. Partner websites will inform you if they will pass your information to us.

• When we meet either face to face or via online meeting platforms.

• When we communicate with each other by post.

• When we talk with each other by telephone.

• When we communicate with each other by email.

• When we communicate with each other by instant messaging.

• When you visit our sites and navigate around the web pages.

• From completed surveys we send you from time to time.

• From subscribing to our newsletters, white papers or other such communications.

• From your interaction with our social media accounts.

In the cases where we are in the course of arranging a contract for you, or have arranged a contract for you in the past, we will also receive data about you via the following methods:

• Details about your energy supply, consumption history, supply numbers, pricing details, plan and contract end dates from energy suppliers, distributors, meter operators, third party databases (such as ElectraLink) and data collection agencies.

• Details about your telecommunications hardware and services, tariffs, rates and contract end dates from your current telecoms providers.

• Credit reference agencies (eg. Experian and Equifax) where required to arrange certain contracts with certain suppliers.

• Publicly held information from Companies House or the Electoral Register.

• Companies that introduce you to us or where we have introduced you to another company.

• Companies that provide data services that will enable us to gather information about your business.

2. How we use your information and why

We are required to ensure that we are processing data under one of the following legal bases:

1. In order to fulfil a contractual requirement with you.

2. We have a legitimate interest in processing your data, given due regard to your interests, rights and freedoms.

3. You have provided us with consent to process your data.

4. We are required to fulfil a legal obligation.

5. We are required to process your data in order to protect yours or another person’s vital interests.

6. Processing is necessary for the performance of a task in the public interest.

Our primary purpose for using your data is to help source you a better contract either with your current provider or by switching you to a new provider. We will process and use your data in order to fulfil the contract we have agreed with you.

Below is a list of how we process personal data, why we do so and the legal basis under which we are operating:

How we use your personal information

To agree a contract on your behalf with an energy supplier, or telecommunications service provider

To search our panel of suppliers in order to obtain the beast quotes available to you

To validate your data against other sources and ensure your information is accurate

To improve our services and provide you with better products and service

To research market trends, customer demographics etc.

To communicate with you about your contracts and agreements we have arranged

Contacting you about renewal quotes for the contracts we have arranged

To send promotional material to you

To send market research/customer sentiment surveys to you

To perfor sanctions/fraud checks

To perform credit searches

To manage fees and recover money that is owed to us

To test our systems, ensure our business is running efficiently, managing communications, our financial reconciliation is performed, audit processes, filing obligations to regulators

To train our staff and ensure that compliance and quality are monitored within the company

To identify your business from partial information you have provided online

To provide third parties with information about you

Why

We will have agreed a contract between us to achieve this on your behalf

To maximise the chances of your agreement going live with the supplier

Allows us to develop profiles of our customers base, develop better processes, making it easier for you to access and use our services

To ensure that you are aware of key dates and requirements of the contracts we have agreed on your behalf with our panel of suppliers

To ensure that you don't end up looked into a rolling contract

To provide you with details of services that we believe could save you money

Help us develop and improve our services

To ensure that we haven't sold a product to someone who has sanctions on their account or provide products to customers who may be using fraudulent personal details.

To detect any financial problems customers may have, detect fraud, manage risk and ensure that customers are given the best products to suit their needs

To ensure any commission we are due from suppliers, or fees due from customers are paid in full

We have numerous obligations we need to comply with to ensure that we are running our business in a correct and compliant manner, from tax legislation, regulatory and legal requirements and annual filling obligations to bodies like the Financial Conduct Authority.

All calls into and out of the business are recorded. We use these calls to monitor the quality of our service and ensure that we are hitting regulatory and legal standards during our sales and customer service process. Certain phone calls such as insurance and energy verbal contracts are required to be recorded to ensure we have proof of a contract between you and a supplier.

Our online application forms gather information about your business, where a customer has only partially completed the form, we will validate the partial information and may contact you using that information.

If you have been introduced to us by a third party, we are required to report back to that third party if you have taken an agreement out through us, additionally we may use third party companies in the course of arranging a contract for you, please see who we share your information with section for further details.

Legal basis for processing

Contractual

Legitimate Interests

Contractual

Contratual and legitimate interests

Consent

Legitimate Interests

Legal obligation

Contractual, Legal Obligation, Legitimate Interests

Contractual, Legal Obligation, Legitimate Interests*

Contractual, Legal Obligation, Legitimate Interests

Legitimate Interests

Contractual

Each process will only operate under one of these legal bases, these are provided to show under what legal bases the various processes we have in our company could be operating under.

3. Who do we share your information with?

When you use our services, agree a contract with a supplier or talk to us about the services we offer we may share your information with the third parties below.

If you would like to know who your information has been shared with in the course of arranging your contracts, then you can request this information at any time.

Our Group Companies

The operating companies within the Group are Tula Group Limited trading as Tula Communications and Tula Energy Limited.

We may choose to sell any or all of the above companies to another company, or we may choose to merge, buy or start a new business. If this happens then the new corporate business will have the same right to use your data as set out in this privacy notice.

Suppliers

Energy

When arranging your energy supply we may share your information with data intermediaries and energy suppliers in order to carry out various checks to provide a quote and ultimately to arrange an energy contract for you.

Telecommunications

When arranging your telecommunications policy, we may provide data to one or more telecom service providers and distributors in order to provide a quote, confirm the technical aspects of your line set up and ultimately to arrange a telecoms contract for you.

General Business

Outside companies we may use in order to develop our products, provide analysis, improve our services to customers, or give advice to us. These could include:

• Advisers - This could be our solicitors, IT suppliers, consultancies. They are likely to provide us advice, and in order to give us the best advice may well require access to some sensitive information.

• Advertisers and analytics providers - These firms, such as Google, Facebook or Twitter, may be given limited information about you if you consent, in order to display targeted relevant messages to you and others about our services.

Other Third Parties

In order to provide our services, we use the services of other third-party companies in order to maximise the probability of your contract going live, or because we have a legal requirement to adhere to eg. alternative dispute resolution, sanctions searches and anti-money laundering legislation.

All of these third parties are strictly forbidden from using your data for any purpose other than those disclosed above, all third parties are rigorously checked out before sharing information with them and are held to the highest standards once they are working for us.

A list of the largest of these third parties is below, with a brief description of the purpose for sending them your information. If you would like to know who we have passed your information to in the course of arranging your contracts, then you can request this information at any time.

• Adobe Sign - Software used to sign e-contracts for the agreements we arrange.

• Creditsafe - Verification of contact and business credit searching.

• Energy Ombudsman - Alternative dispute resolution.

• Online Direct - Verification of meter and contact information for energy contracts.

• Microsoft - Data storage.

• Zoho - Customer relationship management software.

Some of these third parties are not based in the UK or EU, where that is the case we have put in place contracts that ensure they protect your data to the same standards as the UK and EU.

4. How long we keep your information

We will keep your personal information for as long as you are a customer of the Group.

As your contract ends and you no longer wish to use the Group services, we may be required to keep your data for up to 10 years after you stop being a customer. During that time we could use your data for the following processes:

• To respond to a question or a complaint

• To prove that we have arranged valid agreements to our suppliers

• To analyse historical trends, perform internal research or develop our products and services

• To obey tax or anti-money laundering rules around record keeping

We commit to keeping your data safe and secure during this period and will ensure your privacy is protected.

5. Your Legal Rights

Under the Data Protection Act 2018 you have the following rights, this section explains what they are and how they work:

• The right to be informed - We will always explain to you how we are going to use your personal information when you take a contract with us, this could be as part of your application process, or asking how you would like to be marketed to, but will also be set out in the terms and conditions of your agreements with us and within this privacy policy.

• The right of access - You are entitled to request the personal information we hold on you and how we have processed that information. You can do this simply by contacting us via email, letter or phone and we will respond within 30 days. Additionally, you have the right to certain information in a digital format for your own personal use. Please let us know that you would like this option at the point of requesting your personal information.

• The right to rectification - If you believe that any of the personal information we hold is incorrect or out of date, please contact us and we will correct it for you.

• The right to request we stop processing your information, object to us holding it or delete your information completely - You can ask us to delete, remove or stop using your personal information if there is no reason that we should be holding it or processing it. As stated above, there may be a contractual agreement in place, or we have a legal obligation to process or store your data, and in these circumstances we will explain whether we can delete your data or stop processing it, this will not be on all occasions. Broadly speaking, where we have asked for your consent to process your data such as ending marketing emails, you can withdraw your consent at any time; or where we are acting under legitimate interests, you will be able to request we stop processing. We will review any request under this right and provide you with an answer either agreeing to your request, or explaining why we can not.

Our websites may also contain links to and from the websites of our partner networks, suppliers and affiliates. If you follow a link to any of these websites, please note that they will have their own privacy policies and that we do not accept any responsibility or liability for these policies or data activities on such websites. Please check these policies before you submit any personal data to these websites.

6. Cookie Policy

The Group may use cookies and other similar technologies in the operation of our websites.

A cookie is a piece of information that a website puts on your computer so it can remember something about you or your device at a later date. We use cookies to distinguish you from other users of our website (including when you browse other third party websites). This helps us to provide you with a good experience when you browse this website. We also use cookies and similar technologies to show you more personalised advertising, including adverts on other websites. By using our websites, you agree to our use of cookies. This policy explains what cookies, including third party cookies, we use on our website, and how you can refuse or withdraw your consent to cookies. You can find more information about cookies at www.allaboutcookies.org and www.youronlinechoices.eu.

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