Privacy

Last updated: 13/09/2019

 

1. General Privacy Policy

This applies to our customers, suppliers, other business contacts, people who use our website, and anyone who may represent them (for example, their officers, employees or agents). 

 

2. Candidate Privacy Notice

This applies to anyone who is applying for a job vacancy at Valda Energy

 

General Privacy Policy

Introduction

We respect your privacy and we are committed to protecting your personal data. This notice will explain how we look after your personal data and tell you about your privacy rights.

This notice is provided in a layered format so you can click through to the specific areas you are interested in, as set out below.

 

Important information

Purpose of this privacy notice

This notice aims to give you information on how we collect and processes your personal data. It applies to our customers, suppliers, other business contacts, people who use our website, and anyone who may represent them (for example, their officers, employees or agents). We do not intentionally collect data relating to children.

It is important that you read this notice together with any other privacy 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 notice supplements other notices and is not intended to override them.

Controller

The Valda Energy Group is made up of Valda Energy Group Limited (company number 11852539) and Valda Energy Limited (company number 11212563). When we mention we, us or our in this notice, we are referring Valda Energy Limited. This is the relevant company in the Valda Energy Group responsible for processing your data and the controller for the purposes of data protection laws.

Contact details

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this notice. If you have any questions about this notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Email address: dpo@valdaenergy.com

Postal address: Data Protection Officer, Valda Energy, Unit 11, Talisman Business Centre, Talisman Road, OX26 6HR.

Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance (dpo@valdaenergy.com).

Changes to this privacy notice and your duty to inform us of changes

We keep this notice under regular review. This version was last updated on the date stated at the top of this page.

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.

Third party links

Our 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.

Data we collect about you

Personal data 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:

Name

Description

contact data

Email address, telephone number and postal address.

device data

Details about the device used to access our website, including the internet protocol address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform.

financial data

Bank account and payment card details, the results of any credit check, and other information about your financial standing or creditworthiness.

identity data

First name, last name, username or similar identifier, job title, employer or business name, and (where required for a credit check) data of birth and address.

marketing data

your preferences for receiving marketing from us and our chosen partners.

profile data

Details of competitions you have participated in, preferences, feedback, survey responses and other insights about you.

transaction data

Details about payments to and from you and other details of products and services that we have supplied to you or which we have requested from you. If you are a customer, this includes details of the premises supplied or to be supplied by us, the metering systems installed at those premises, the persons appointed to provide services in respect of those metering systems, the energy consumption at those premises, your charges, appointments made with you, details of any vulnerable persons at those premises, any industry schemes you are participating in, records and notes of communications and performance, and your authorised representatives.

website data

information about how you use our website and services made available through it.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your website 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 notice.

We do not routinely 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). We may, however, be given information about the health of any vulnerable people resident at premises we supply where it is relevant to an action we may take (for example, if we consider it necessary to disconnect your premises).

We may also collect information about criminal convictions and offences in the course of performing our legal duty to detect and prevent certain criminal activity associated with the supply of energy.

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 supply you with energy). In this case, we may have to cancel your contract with us but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including:

Method

Description

directly from you

You may give us your identity data, contact data, financial data, transaction data, marketing data and profile data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

·             apply for our products or services;

·             create an account on our website;

·             subscribe to any of our newsletters;

·             request marketing to be sent to you;

·             enter a competition, promotion or survey; or

·             give us feedback or contact us.

automated interactions

If you are a customer, we may automatically collect transaction data through your metering system or industry data flows.

We automatically collect device data and website data if you interact with our website. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.

third parties / publicly available sources

We may receive personal data about you from various third parties and public sources as set out below:

·             identity data, contact data, financial data and transaction data from intermediaries, such as employees of your organisation and energy brokers and managing agents, based inside or outside the EU;

·             identity data and contact data from landlords where there has been a change of tenancy at premises supplied by us, based inside and outside the EU;

·             identity data and contact data from a previous supplier to your premises, based inside the EU;

·             identity data and contact data from publicly available sources, such as your website(s) and social media accounts, Companies House, the Electoral Register and Land Registry, based inside and outside the EU;

·             financial data from credit reference agencies, based inside and outside the EU;

·             financial data and transaction data from payment and debt collection service providers, based inside and outside the EU;

·             transaction data from industry appointees and providers of metering services, based inside the EU;

·             device data and website data from analytics providers, based inside and outside the EU; and

·             identity data, contact data and transaction data from third party organisations to whom you may make a complaint or otherwise report a concern, based in the UK.

 

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 it is necessary to perform a contract to which you are a party or to take steps at your request before entering into such a contract;
  • where it is necessary for our legitimate interests (or those of a third party). This 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.
  • where it is necessary for us to comply with a legal obligation that we are subject to; or
  • where it is necessary to detect or prevent any unlawful act.

Generally, we do not rely on consent as a legal basis for processing your personal data, although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

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 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.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer, including:

·       performing a credit check;

·       becoming the registered supplier for your premises; and

·       setting up a Direct Debit payment.

·       identity data

·       contact data

·       financial data

·       transaction data

·       Performance of a contract with you.

·       Necessary for our legitimate interests (to understand your ability to pay our charges).

To supply energy to you, including:

·       sending industry data flows to ensure you receive requested services and you are charged the right amount;

·       managing payments and charges; and

·       collecting and recovering money owed to us.

·       identity data

·       contact data

·       financial data

·       transaction data

·       Performance of a contract with you.

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

To manage our relationship with you, which may include:

·       notifying you about changes to our terms or privacy notice;

·       notifying you about matters affecting your supply of energy; and

·       asking you to leave a review or take a survey.

·       identity data

·       contact data

·       financial data

·       transaction data

·       Performance of a contract with you.

·       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/services).

To make suggestions and recommendations to you about goods or services that may be of interest to you.

·       identity data

·       contact data

·       marketing data

·       profile data

·       transaction data

·       Necessary for our legitimate interests (to develop our products/services and grow our business).

·       Necessary to comply with a legal obligation (for example, for smart metering).

To enable you to partake in a prize draw, competition or complete a survey.

·       identity data

·       contact data

·       marketing data

·       profile data

·       transaction data

·       Necessary for our legitimate interests (to study how customers use our products/services, and to develop them and grow our business).

To deliver relevant content and marketing to you and measure or understand the effectiveness of the marketing we serve to you.

·       identity data

·       contact data

·       marketing data

·       profile data

·       transaction data

·       website data

·       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 administer and protect our business (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, prosecution or defence of legal proceedings).

·       identity data

·       contact data

·       financial data

·       profile data

·       transaction data

·       website data

·       Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud, in the context of a business reorganisation or group restructuring exercise, and to protect our legal rights).

·       Necessary to comply with a legal obligation.

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.

·       profile data

·       transaction data

·       website data

·       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 respond to a request for information from, or comply with any direction given by, a regulatory authority.

·       identity data

·       contact data

·       financial data

·       transaction data

·       Necessary to comply with a legal obligation.

To detect, investigate and prevent criminal activity in relation to the supply of energy, including:

·       sharing information with the Theft Risk Assessment Service (see here [INSERT LINK TO “THEFT RISK ASSESSMENT SERVICE” BELOW] for details); and

·       assist law enforcement agencies and other public authorities (for example, Trading Standards).

·       identity data

·       contact data

·       financial data

·       transaction data

·       Necessary to comply with a legal obligation.

·       Necessary for our legitimate interests (to prevent financial loss).

·       Necessary to prevent or detect an unlawful act.

 

 

Theft Risk Assessment Service

The Theft Risk Assessment Service (TRAS) is a data analytics service set up by the energy industry to help suppliers assess the risk of energy theft at premises they supply and to target theft investigations. TRAS uses data provided by all suppliers and combines it with information from other sources to identify instances of unusually low consumption that may indicate theft. Suppliers may then investigate these instances.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Customers can view and make certain decisions about their marketing preferences in our customer portal.

Promotional offers from us

We may use your identity data, contact data, profile data, transaction data and marketing 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 purchased goods or services from us and you have not opted out of receiving that marketing.

Third party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time. Our customers may log into our customer portal to check or uncheck relevant boxes to adjust their marketing preferences, but everyone can follow the opt-out links on any marketing message sent to them.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

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.

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.

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

  • debt collection agencies and revenue protection service providers;
  • industry bodies and participants (for example, industry code administrators, other energy suppliers, the owners and operators of the energy supply infrastructure);
  • intermediaries authorised to act on your behalf (for example, your energy broker or managing agent);
  • intermediaries authorised to act on our behalf (for example, sales agents);
  • providers of metering services (for example, meter asset providers, meter operator agents, meter asset manager, data readers, data collectors, data aggregators);
  • providers of IT and system administration services;
  • regulators, law enforcement agencies and other authorities (for example, the Office of Gas and Electricity Markets (Ofgem), HM Revenue & Customs, the police, Trading Standards);
  • website analytics providers; and
  • your landlord (where you are a customer at premises supplied by us).

In addition, we may share some personal data with 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 notice.

We require all third parties who process your personal data on our behalf 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.

International transfers

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Please contact us (dpo@valdaenergy.com) if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

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. 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 it. 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.

Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available on request from.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

In some circumstances we will 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.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at privacy@valdaenergy.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 could 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 could 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.

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 to erase personal data 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:
    • if you want us to establish the data’s accuracy;
    • where our use of the data is unlawful but you do not want us to erase it;
    • 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
    • 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.

 

Candidate Privacy Notice

What is the purpose of this document?

Valda Energy Limited (company number 11212563) is a “controller”. This means that we are responsible for deciding how we hold and use personal information about you. You are being sent a copy of this privacy notice because you are applying for work with us (whether as an employee, worker or contractor). It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR).

Data protection principles

We will comply with data protection law and principles, which means that your data will be:

  • used lawfully, fairly and in a transparent way;
  • collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
  • relevant to the purposes we have told you about and limited only to those purposes;
  • accurate and kept up to date;
  • kept only as long as necessary for the purposes we have told you about; and
  • kept securely.

 

The kind of information we hold about you

In connection with your application for work with us, we will collect, store, and use the following categories of personal information about you:

  • the information you have provided to us in your curriculum vitae and covering letter;
  • the information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications; and
  • any information you provide to us during an interview or which we collect in the course of an assessment exercise.

We may also collect, store and use the following types of more sensitive personal information: information about your health, including any medical condition, health and sickness records; and

How is your personal information collected?

We collect personal information about candidates from the following sources:

  • you, the candidate;
  • the recruitment agency that introduced you, from which we collect the following categories of data: name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications;
  • your named referees, from whom we collect the following categories of data: employment history and suitability for the role; and
  • publicly accessible information you post online, such as on your LinkedIn profile, from which we collect the following categories of data: employment history and qualifications.

 

How we will use information about you

We will use the personal information we collect about you to:

  • assess your skills, qualifications, and suitability for the role;
  • carry out reference checks, where applicable;
  • communicate with you about the recruitment process;
  • keep records related to our hiring processes; and
  • comply with legal or regulatory requirements.

It is in our legitimate interests to decide whether to appoint you to a role since it would be beneficial to our business to appoint someone to that role.

We also need to process your personal information to decide whether to enter into a contract with you.

Having received your CV and covering letter or your application form (as the case may be), we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. We may arrange a short telephone interview with you to assist this process. If you are shortlisted for the role, we will decide whether your application is strong enough to invite you for an interview. You will be advised in advance if you will also be required to undertake a test or other assessment when you come for an interview.

If we decide to call you for an interview, we will use the information you provide to us at the interview and the results from any test or other assessment to decide whether to offer you the role. If we decide to offer you the role, we will then take up references before confirming your appointment.

If you fail to provide personal information

If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.

How we use particularly sensitive personal information

We will use your particularly sensitive personal information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process; for example whether adjustments need to be made during a test or interview.

Information about criminal convictions

We do not envisage that we will process information about criminal convictions.

Automated decision-making

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

Data sharing

We will only share your personal information with recruitment agents appointed in respect of the role for the purposes of processing your application.

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

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

Data retention

We will retain your personal information for a period of six months after we have communicated to you our decision about whether to appoint you to a role. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with our data retention policy.

If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.

Rights of access, rectification, erasure, and restriction

Under certain circumstances, by law you have the right to:

  • request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it;
  • request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
  • request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below);
  • object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes;
  • request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it;
  • request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Privacy team at privacy@valdaenergy.com.

Data protection officer

We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO at privacy@valdaenergy.com. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.