GTC App – Privacy Policy

This policy sets out how GTC Infrastructure Limited (“we”, “our”, “us”, “GTC”) will treat any personal information which we receive from you via the GTC App (whether you use the GTC App via a web browser or on a mobile device).

We are committed to safeguarding personal information. We have developed this policy because we want you to feel confident about the privacy and security of your personal information.

For the purposes of the Data Protection Act 2018, the UK GDPR (as defined in the Data Protection Act 2018), and any other applicable data protection legislation (together, the “Data Protection Legislation”), the data controller is GTC Infrastructure Limited, a Guernsey registered company with registered number FC020169 and with a branch established in England and Wales under branch number BR003827 and address at Synergy House Woolpit Business Park, Bury St Edmunds, Woolpit, IP30 9UP.

We may hold and use your personal information in your capacity as a user of the GTC App, but only in connection with your right to use the GTC App, which is dependent upon your employment within your role as a representative of one of our developer customers.

Such personal information may include your name, contact details (being your email address, office address and telephone number) and place of work. We may also collect and/or receive information about your usage of the GTC App and the content you post to the GTC App, as well as personal information and information collected via cookies. Please refer to our Cookie Policy for more information about the use of cookies on the GTC App.

Once we are holding your personal information, we will only handle such data in accordance with this Privacy Policy and the Data Protection Legislation.

We do not envisage that your use of the GTC App will result in our processing of any sensitive personal information (being personal information which concerns racial or ethnic origin, political opinion, religious beliefs or other beliefs of a similar nature, membership of a trade union, physical or mental health or conditions, sexual life, commission or alleged commission of any offence or any proceedings for any offence committed or alleged to have been committed by you, the disposal of such proceedings or the sentence of any court in such proceedings) relating to you. However, any sensitive personal information that we do process (for example, where it is inadvertently provided by you) will be processed in accordance with this privacy policy and the Data Protection Legislation.

Your personal information will be used for the purposes specified in this Privacy Policy.

We may use your personal information to:

• provide our services, including services available on the GTC App;
• run our business affairs, including internal record keeping;
• contact you where necessary about our services;
• deal with enquiries and complaints;
• provide you with access to the relevant parts of the GTC App;
• undertake our statutory obligations as a licenced multi-utility operator;
• help us distribute multi utilities safely;
• respond to interruptions as multi utility operator;
• provide you with useful and informative advice;
• from time to time, issue SMS messages with an optional web incept surveys link to gather your feedback to improve your experience with GTC;
• enable compliance with statutory and legal obligations and requests; and
• contact you in an emergency,

and for any other purposes set out in our Cookie Policy.

We primarily process your personal information on the basis that it is necessary for our legitimate business interests in fulfilling the above purposes. In some instances, we will process your personal information on the basis that it is necessary for our compliance with legal obligations, to allow us to perform or enter into a contract with you, or for the performance of a task carried out in the public interest.

In some instances, we may rely on your express consent to use your personal information, but we will let you know (and give you the chance to withdraw consent) if we do. If you have provided your consent to us processing your personal information in a particular way but you later change your mind, please let us know by contacting us using the details set out in the “Privacy Support” section below.

In order to provide our services, we may share your personal information with:

• our employees, officers and agents;
• our group companies, noting that GTC is part of the BUUK Infrastructure group of companies;
• our third party business partners, suppliers, subcontractors and service providers;
• other providers of essential services, such as gas transporters, electricity distributors or water companies, local authorities and the emergency services;
• analytics providers that assist us with improvement of the GTC App;
• government agencies and independent regulatory bodies, such as the Office of Gas and Electricity Markets (Ofgem); and
• other third parties as might be required by law, including compliance with any court order or legal obligation.

If our business enters into a joint venture with, purchases or is sold to or merges with another business entity, your personal information may be disclosed or transferred to the target company, our new business partners or owners or their advisors.

We may use your personal information if we are under a duty to disclose or share your information in order to comply with (and/or where we believe we are under a duty to comply with) any legal obligation; or in order to enforce our contracts; or to protect our rights, property, or safety or the rights, property, or safety of our customers, employees or others. This includes exchanging information with other companies and other organisations for the purposes of fraud protection and prevention.

Your personal information may also be transferred to, and stored at, a destination outside the United Kingdom (“UK”). It may also be processed by staff operating outside the UK who work for us or for one of our suppliers. This includes staff engaged in, among other things, the provision of support services. We will only transfer your personal information (a) to recipients in countries that are the subject of an adequacy decision under the Data Protection Legislation; or (b) to recipients in other countries if we have provided adequate safeguards for your personal information in accordance with the Data Protection Legislation (such as the contractual safeguards specified in the Data Protection Legislation).

We take reasonable technical and organisational precautions to protect your personal information from unauthorised access and against unlawful processing, accidental loss, destruction and damage. We will only keep your personal information for as long as we reasonably require and, in any event, only for as long as Data Protection Legislation allows.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will take steps to protect your personal information, we cannot guarantee the security of your personal information transmitted over the internet, including via the GTC App (whether you make use of the GTC App via a web browser or mobile device), and any transmission is at your own risk.

When you create an account to access the GTC App (for further information, please refer to our Terms of Use), you will also create a password – you are responsible for keeping these confidential. You should not share your password with anyone. We will not ask you for your password (except when you log in to the GTC App).

In certain circumstances and subject to certain exemptions, you have the following rights in relation to the personal information that we hold about you:

• the right to be informed about how we are using your personal information;
• the right to access the personal information that we hold about you;
• the right to request the correction of inaccurate personal information that we hold about you;
• the right to ask us to erase or stop processing any personal information we hold about you where there is otherwise no longer a legal ground for us to hold it;
• the right to ask us to restrict the processing of your personal information;
• the right to request that we transfer certain personal information;
• the right to withdraw consent to any consent-based processing at any time; and
• rights in relation to automated decision-making and profiling.

If you wish to exercise any of these rights, please contact us using the contact details set out below. The supply of appropriate evidence of your identity may be required when exercising your rights.

Should you have any queries or complaints in relation to how we use your personal information, please contact us via the details set out below. Should you wish to take any complaints or queries further, you have the right to contact the Information Commissioner’s Office (which is the supervisory body in the UK) regarding such issues.

Please ensure that any personal information you provide us with is accurate and complete and you notify us of any changes to your personal information as soon as possible so that we can update our records.

We may update this privacy policy from time-to-time, at our sole discretion, effective immediately upon the posting of a new version on the GTC App. Please check the GTC App regularly to ensure you are familiar with the current version. Any revised versions will also be presented via the GTC App on your login page.

Should you wish to exercise any of the rights set out above, or if you have any questions or concerns about the way in which we handle your personal data, please contact us at Synergy House, Woolpit Business Park, Woolpit, Bury St Edmunds, Suffolk, IP30 9UP; or email via [email protected].

Alternatively, you have the right to make a complaint to the Information Commissioner’s Office (which is the supervisory body in the UK).