Welcome to Lightsource Labs Australia Pty Ltd (Lightsource Labs) privacy notice.
Lightsource Labs respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data as a valued Lightsource Labs customer and tell you about your privacy rights and how the law protects you.
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how Lightsource Labs collects and processes your personal data through your interaction with us and use of your System in accordance with your PPA.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Lightsource Labs is made up of different legal entities. This privacy notice is issued on behalf of the Lightsource Labs group so when we mention Lightsource Labs, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Lightsource Labs group responsible for processing your data. Lightsource Labs Renewable Energy Investments Limited is the controller and responsible for this website.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your opt-out right, please contact the DPO using the details set out below.
Our full details are:
Full name of legal entity: Lightsource Labs Australia Pty Ltd
Name or title of DPO: Carol Mitchell
Email address: firstname.lastname@example.org
Postal address: Level 7, 33 Holborn, London, EC1N 2HU
You have the right to make a complaint at any time to the Office of the Australian Information Commissioner, the Australian supervisory authority for data protection issues https://www.oaic.gov.au/. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on 25 May 2018.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
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 notice of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
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 Data includes first name, maiden name, last name, username or similar identifier, title, date of birth and gender.
- Contact Data includes email address and telephone numbers.
- Transaction Data includes details of products and services that you have engaged with us.
- 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 and any web based monitoring platform which we provide you with access to in accordance with the PPA.
- Profile Data includes your interests, preferences, feedback.
- Usage Data includes information about how you use our website, products and services. Specifically, this includes collecting personal data from the System regarding your historical energy and power generation and/or consumption.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 which will be used in accordance with this privacy notice.
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.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity and Contact Data by filling in forms (including but not limited to the PPA, ancillary documents to the PPA and electronic forms generated by this website or the monitoring platform) or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- enquire and/or apply for our products or services;
- subscribe to our service or publications;
- request marketing to be sent to you; or
- give us feedback.
- Automated technologies or interactions. As you interact with this website or the monitoring platform, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Similarly, the monitoring platform and the System itself issued in accordance with the terms of the PPA will automatically collect Technical Data, Profile Data, Usage Data and Marketing and Communications Data.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources such as Identity and Contact Data from publicly available sources such as Companies House and Technical Data from analytics providers such as Google.
4. 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 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 interests (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.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email, electronica notification or text message. You have the right to withdraw consent to marketing at any time by contacting us at the following email address email@example.com.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at firstname.lastname@example.org if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Type of data
|Lawful basis for processing including basis of legitimate interest
|To identify and register you as a potential or new customer/client and/or for incorporation into our client relationship system.
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to grow our business and/or respond to requests and enquiries from you)
|To manage our relationship with you which will include:
(b) Providing you with invoices in accordance with the terms of the PPA
(c) To provide you with the monitoring platform to allow you to track historical energy and power generation and/or consumption
(d) Monitoring the performance of the System and maintaining the System
(g) Marketing and Communications
|(a) Performance of a contract with you (invoicing, monitoring and maintenance)
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated, keep customers updated, optimising the system, to study how customers use our products/services)
|To administer and protect our business, the monitoring platform and this website (including troubleshooting, invoicing, data analysis, testing, system maintenance and optimisation, support, reporting and hosting of data)
(f) Marketing and Communications
|(a) Performance of contract with you (invoicing, monitoring, maintenance, troubleshooting, support and hosting of data)
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (for running our business, to study how customers use our products/services, reporting)
|To deliver relevant website content
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
|To use data analytics (either carried out directly by Lightsource Labs or a third party provider) to improve our website, products/services, marketing, customer/client interface, relationships and experiences, creating energy efficiencies or savings for you
|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)
|To provide information and make suggestions, promotions and recommendations to you about goods or services offered by Lightsource Labs or other third party companies that might be of interest of you regarding energy efficiencies and savings
(f) Marketing and Communications
|Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
ADVERTISING FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or have an existing service relationship with us and, in each case, you have not opted out of receiving that marketing.
We have provided you with an opt-in consent check box when you complete an enquiry form on our website or the monitoring platform notifying us of your request to receive any marketing and advertising material from us.
We do not sell personal information collected through this site.
We will get your express opt-in consent before we share your personal data with any company outside the Lightsource Labs Group of companies for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at email@example.com.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of product/service experience or other transactions.
Cookies may be used by us to provide you with customised information from our website. A cookie is an element of data that a website can send to your browser, which may then store it on your system. Cookies allow us to understand who has seen which pages and advertisements, to determine how frequently particular pages are visited and to determine the most popular areas of our website. Cookies may also allow us to make our website more user friendly by, for example, allowing us to save your password so that you do not have to re-enter it every time you visit our website.
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 firstname.lastname@example.org.
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 the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Internal Third Parties as set out in the Glossary section below.
- External Third Parties as set out in the Glossary section below.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
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.
6. DATA SECURITY
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.
All data collected by us is stored on a secure server. The secure server software encrypts all information you input before it is sent to us.
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.
7. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We 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.
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 requirements.
By law we have to keep basic information about our clients/customers (including Contact, Identity, and Transaction Data) for six years after they cease being clients/customers for tax purposes.
In some circumstances we may 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.
8. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
If you wish to exercise any of the rights which are set out under the glossary section below, please contact us at email@example.com.
NO FEE USUALLY REQUIRED
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 may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
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.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may 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.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at firstname.lastname@example.org.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
INTERNAL THIRD PARTIES
Other companies in the group acting as processors.
EXTERNAL THIRD PARTIES
- Service providers acting as processors who provide administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.