This policy provides an overview of how GB Marginal Gains Limited (Marginal Gains) use any personal information that you give us, what information is collected and how to contact us in relation to a query with about information.
Who we are
When we say ‘we’, ‘us’, or ‘our’ in this notice we are referring to GB Marginal Gains Limited a company registered in England and Wales (Registration Number: 11938396)
What information do we hold?
This may include: –
- Your name and contact information including email addresses, postal addresses, telephone number
- Information regarding your personal preferences, product selections and marketing preferences in order provide you with information on products and services in the future.
What do we do with this information?
We will use the information provided by you to conduct normal business operations with an aim of providing a better overall service.
This includes: –
- To confirm your identity when you contact us
- Contacting you regarding any products, special offers or promotions that may be of interest to you.
- Setting up and administering a contract or agreement
- To process information pack enquires via post/email/telephone
- To track activity on our website
- Fulfilling legal or regulatory obligations
Providing you with a quote
When you request a quote from us via our website, or by email, or telephone, we will need to collect the following information about you to allow us to provide that quote:
- First and last name;
- Business name;
- Postcode of your business;
- Email address;
- Telephone number;
- Type of energy quote;
- Meter point administration number (MPAN);
- Meter point reference number (MPRN);
- How much electricity and/or gas you use – you can provide this in pounds or kilowatts per year/6-monthly/quarterly/monthly.
We will not be able to provide a quote to you unless you provide the information shown in above. As we prepare your quote, we may use your MPAN number to check with third party databases to determine what type of meter you are using. This will help us to provide an accurate quote to you.
If you join us as a customer, we will need to collect the following additional information about you to allow us to complete the customer onboarding process (including verifying your identity and carrying out a credit check)* and to provide to you the products or services you have requested from us or our partners:
- Personal details – title, name, phone number, email address, time at address;
- Job title (where you are acting on behalf of a limited company);
- Date of birth (of sole traders and partners – for credit checking (see below));
- Domestic address(es) (of sole traders and partners – for credit checking (see below);
- Contact / billing address;
- Business bank account details.
If it is required in order to take over your energy supply, we may ask your previous energy supplier for information about you, including information about your metering equipment, meter readings and any charges you may owe your previous supplier.
Where do we get your information?
Most of the information we receive comes directly from you however we may also get personal information about you from other sources. These include: –
- Consumer Data brokers/ suppliers.
- Registered Introducers (e.g. accountants)
- Registered Partners (e.g. business services companies)
How are you able to process my data?
Data Protection regulation (including the Data Protection Act (DPA) and General Data Protection Regulation (GDPR) gives organisations several different conditions to allow us to process your information lawfully.
We will only use your personal information when one of these conditions has been fulfilled. Below you can see how we use your information and our legal grounds for processing it.
Contract – we or our partners have a contract with you to deliver a product and service. To perform and administer that contract we need certain information from you; for example, your contact details.
Legal basis – in some circumstances we are compelled by law to process your information. For example, the law recognises that processing data for certain purposes is in the substantial public interest. We also need certain information from you to meet our legal obligations, such as confirmation of identity. This allows us to meet our fraud and anti-money laundering obligations.
To meet our legitimate interests – we may use your information for our legitimate business interests if we are open and transparent with you about this. Our business interests are to improve and develop the products and services within our business. For example, we may market products and services to you that we think will be of interest to you. When we process personal information for this purpose we put in place robust safeguards to ensure that your privacy is protected and that our legitimate interests do not override your interests or fundamental rights and freedoms.
Consent – there may be times when we need to obtain your explicit consent to collect and use your personal information (for example; when we need to send you marketing messages by email, text, and other electronic means). If we ask for your consent to process your information, you have the right to withdraw your consent at any time. Please see the section ‘Your rights’ below for further information.
Who do we share this information with?
At times we may need to share the information we have to provide or deliver a service to you. We will ensure that we are processing your data in line with our obligations under Data protection legislation and that you are kept informed at the point your data is shared.
Examples of who your data may be shared with: –
The Marginal Gains Group use more than one company to deliver our products and services to you. We may share your data with other companies as part of our commitment to offer you products and services that may be of interest to you.
Product providers – we use third party companies to provide products and services to our customers. For example, energy suppliers, merchant service companies.
Service providers – we use third party companies to deliver business services and audit business activities.
Regulatory, government, and industrial bodies – these include HM Revenue and Customs, Home office, Land Registry, Law Enforcement Bodies, and Fraud Prevention Organisations. This is to comply with our legal and regulatory obligations, this may include acting in accordance with best practice.
Other Third Parties – In the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets. If GB Marginal Gains Limited or substantially all of its assets are acquired by a third party, in which case personal information held by it about its customers will be one of the transferred assets.
Anyone you ask us to share your information with – if you ask us to share your information, for example with a trustee, executor, or professional advisor we will check with you to confirm that the person requesting information on your behalf has your permission.
Where is your information processed?
We operate primarily in the United Kingdom. However, sometimes the information that we collect from you may be viewed from, transferred to, or stored, outside of the European Economic Area (EEA).
We ensure that we put in place appropriate safeguards when we allow your information to be processed outside of the EEA. Please contact our team using the details located at the end of this document if you would like more information on the appropriate safeguards we have in place.
How long do we retain your information?
As a business we need to retain your information to carry out several activities and meet our legal obligations. These include: –
- Maintain business records for analysis and/or audit purposes;
- Comply with record retention requirements under the law;
- Defend or bring any existing or potential legal clams; and
- Deal with any complaints regarding our products or services.
- Maintain relevant records of customers marketing preferences including requests not to receive marketing communications.
We will delete your personal information when it is no longer required for these purposes.
If you no longer have any relationship with us (i.e. you have not taken a product or have not opted to receiving marketing communications from us) then we will store your information up to 3 years from our last communication with you.
If you have taken a policy with us or opted in to receive marketing communications, we will store your information until you either end that relationship (i.e. cancel your product) and/or opt out of future marketing communications.
What are your rights?
As part of Data protection legislation, you have rights around how personal information around you is handled and processed.
If you would like to exercise these rights, please contact our team.
Our contact details can be found in the ‘Contact us’ section at the end of this document.
Stop using your information – If you don’t want us to use your information you can ask us to stop and we will do so unless there is an important reason why we need to continue using it.
Accessing your information – You have the right to ask for a copy of the information we hold about you (known as a Subject Access Request). You can make a Subject Access Request by contacting our team. We will take reasonable steps to confirm your identity before providing you with any personal information we hold about you.
Accessing your information from our partners – You have the right to ask for a copy of the information held about you (known as a Subject Access Request) by our partners. You can make a Subject Access Request by contacting them directly on the email address provided to you in correspondence.
Transferring your information – You can request that we transfer information we hold about you or a third party in electronic form.
Removing your information – In certain circumstances you can ask us to stop using or holding your information. If we can delete your information entirely we will, but sometimes we must maintain records for legal reasons. If we cannot comply with your request, then we will contact you and explain why.
Updating your information – It is important that the information we hold about you is accurate. You can let us know if your information changes, or if the information we hold about you is incorrect. You can ask our team to update your personal information free of charge.
If we have disclosed your personal information to another company (including another company within the Marginal Gains group), we will also let them know about the changes unless it is impossible or extremely difficult to do so.
Withdrawing Consent – If you have given consent for us to use your information then you have the right to withdraw your consent at any time. Our team will be able to explain to you the consequences of withdrawing consent, and the implications for the continuation of the product or policy that you have with us.
If we have shared your information with another company, we will also let them know that you have asked us to stop using or retaining your information unless it is impossible or extremely difficult to do so.
Right to complain to supervisory Authority – If you are unhappy with the way we are using your information, you have the right to complain to the Information Commissioner’s Office. Please feel free to contact us first to discuss your concerns.
The Information Commissioner’s Office can be contacted at Wycliffe House, Wilmslow, Cheshire, SK9 5AF.
How do you tell me about changes?
Changes to the way we use your information
If we want to use your personal information for a new purpose which we haven’t previously told you about, we will contact you to explain the new use of your information. We will set out why we are using your information and our legal reasons for doing so.
This policy was last updated 1st January 2020.
How can I get in contact with you?
If you have any questions or concerns about our use of your information, or would like a copy of the information we hold about you, please contact our team using the following details:
Marginal Gains Limited
Consett Business centre