Privacy Policy

We are Lightsource Labs Australia Pty Ltd trading as Tribe (Tribe).

Tribe respects your privacy and is committed to protecting your personal information.  This policy explains how we manage personal information within our organisation. This privacy policy only applies to people in Australia.

Purpose of this privacy policy

This privacy policy aims to give you information on how Tribe collects and processes your personal information through your interaction with us and use of your Tribe Energy Management System (Tribe Solution) in accordance with your Subscription Agreement.

The Tribe Solution comprises the Tribe Hub and Tribe App.

Kinds of personal information we collect

We may collect and hold the following kinds of information:

• Identity Information including first name, last name, username or similar identifier, title, date of birth and gender.
• Contact Information including physical address, mailing address, email address and telephone numbers.
• Transaction Information including details of products and services that we provide to you and billing in relation to the products and services.
• System Information such as the Tribe Hubs you are using, their location and the configuration of other devices on your network.
• Technical Information for the devices you use to access the Tribe Solution and to communicate with us including internet protocol (IP) address, device type, your login data, app version, 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 the Tribe Solution and our website.
• Profile Information including your interests, preferences and feedback.
• Usage Information including information about how you use the Tribe Solution, our website, products and services. Specifically, this includes information from the Tribe Solution regarding your energy and power generation and consumption that the Tribe Solution collects and processes, including data collected from solar panels, batteries and the electric grid.
• Marketing and Communications Information including your preferences in receiving marketing from us and our third parties, your communication preferences and the marketing that we send to you and your response to such marketing.

How we collect personal information

We collect personal information about you in the following ways:

• when you register for a subscription with us;
• when you purchase our products or services;
• when you use the Tribe Solution (which may collect information automatically);
• when you submit a query or request to us;
• when you respond to a survey that we run or fill in forms on our Tribe App or website;
• by tracking your use of the Tribe App and website;
• from public sources;
• when you seek customer support;
• when you communicate with us;
• automatically through the Tribe App and website through cookies and other similar technologies; and
• from third parties who are entitled to disclose that information to us.

Purposes for which we use personal information

We use personal information that we collect about you for the following purposes:

• to identify and register you as a potential or new customer and to enter into a Subscription Agreement with you;
• to include you into our client relationship system;
• to enable us to provide our products and services to you, including the Tribe Solution;
• to notify you about updates, changes and new features to the Tribe Solution;
• to operate the Tribe Solution;
• to manage our relationship with you, including:
• notifying you about changes to your Subscription Agreement or this privacy policy; and
• monitoring the performance of the Tribe Solution;
• to administer and protect our business, the Tribe Solution and our website;
• to provide you with relevant information including via our Tribe App, website and emails;
• to analyse data (for example, data analytics either carried out directly by us or through a third-party provider) to improve our products and services, provide marketing material and enhance the customer experience;
• to provide information and make suggestions, promotions and recommendations to you about goods or services that we offer; and
• to comply with our legal and regulatory obligations.

We may from time to time use your personal information in order to send you marketing materials about products or services that we think you may be interested in (including in some cases products and services that are provided by a third party).

You can opt-out of receiving marketing communications from us by contacting us at privacy@lightsourcebp.com

We may also use and disclose your information for other purposes as authorised by you, or in accordance with your requests or instructions.

Without this information we may not be able to provide you with our products or services (or with all of the features and functionality offered by our products or services) or to respond to queries or requests that you submit to us.

De-identified information

We may de-identify information about you so that the information can no longer be related to you.  We may then use and disclose that de-identified information in the course of our business.

We may also aggregate information about your use of our products and services in such a way that the information is no longer related to you.  We may then use such aggregated information in the course of our business.

People to whom we disclose personal information

We may share personal information about you with:

• other users of the Tribe Solution who you have authorised to have access to your Tribe account;
• your representatives, advisers and others you have authorised to interact with us on your behalf;
• our staff and contractors who need the information to discharge their duties;
• related entities within the Tribe group;
• our business partners, channel partners, agents and service providers;
• prospective purchasers of all or part of our business or shares in our company or that of a related entity;
• professional advisers who we engage to provide advice on our business;
• installers;
• electricity retailers; and
• government authorities who ask us to disclose that information, or to other people as required by law.

In some cases the people to whom we disclose your personal information may be located outside of Australia and may be subject to different privacy regimes.  The countries in which these people are likely to be located include England, Wales, Ireland and Spain.

Cookies

We use cookies to monitor and observe your use of our website, compile aggregated data about that use, and provide you with a more effective service (which may include customising parts of our websites based on your preferences and past activities on those websites).

“Cookies” are small text files created and stored on your hard drive by your internet browser software, in order to hold relevant information about the web page you are currently viewing.

Most internet browsers have a facility that will allow you to disable cookies altogether – please refer to your browser’s help menu to find out how to do this.  While you will still be able to browse our websites with cookies disabled on your internet browser, some website functionality may not be available or may not function correctly.

Storage and security of personal information

We store personal information for as long as it is needed for the purpose for which it was collected or as required by law.  We generally store the personal information that we collect in electronic databases, some of which may be held on our behalf by third party data storage providers.  Sometimes we also keep hard copy records of this personal information in physical storage facilities.  We use a range of physical and technical security processes and procedures to protect the confidentiality and security of the information that we hold, and we update these from time to time to address new and emerging security threats.

It is possible that we, or our subcontractors, will use cloud technology in connection with the storage of other personal information, and it is possible that this may result in off-shore storage.  It is not practicable for us to specify in advance which country will have jurisdiction over such off-shore activities.  However, all of our subcontractors are required to comply with the Privacy Act 1988 (Cth) in relation to the transfer or storage of personal information outside of Australia.

We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Third-party links

Our website and app 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 or app, we encourage you to read the privacy policy of every website you visit.

Access and correction

We take reasonable steps to ensure that any of your personal information which we hold is accurate, complete and up-to-date.  These steps include promptly updating personal information when we are advised that the information has changed, checking our contact lists for accuracy, and providing individuals with a simple means to update their personal information.  It is important that the personal information we hold about you is accurate and current.  Please keep us informed if your personal information changes during your relationship with us.

If you want to access any of the personal information that we hold about you or to correct some aspect of it (eg. because you think it is incomplete or incorrect), please contact us using the contact details set out below.  To protect the integrity and security of the information we hold, we may ask that you follow a defined access procedure, which may include steps to verify your identity.  You will not have to pay a fee to access your personal information.  However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, but we will inform you of this before proceeding.    Alternatively, we may refuse to comply with your request in these circumstances.

There may be cases where we are unable to provide the information you request, such as where it would interfere with the privacy of others or result in a breach of confidentiality.  In these cases we will let you know why we cannot comply with your request.

Complaints

We try to meet the highest standards in order to protect your privacy.  However, if you are concerned about the way in which we are managing your personal information, please contact us using the contact details set out below.  Complaints must be lodged in writing.  We will deal with the matter within a reasonable time and will keep you informed of the progress of our investigation.

If we have not responded to you within a reasonable time or if you feel that your complaint has not been resolved satisfactorily, you can contact us to discuss your concerns.  You are also entitled to make a complaint to the Office of the Australian Information Commissioner (OAIC).  Contact details can be found at the OAIC’s website:  www.oaic.gov.au

Changes to this policy

We may make changes to this policy from time to time, to account for changes to our standard practices and procedures or where necessary to comply with new laws and regulations.  The latest version of this policy will always be available on our website and app.

Contact details

If you need to contact us or want any further information from us on privacy matters, please contact our privacy manager Carol Mitchell at:

 

Email:               privacy@lightsourcebp.com
Address:           Level 7, 33 Holborn, London, EC1N 2HU