PRIVACY POLICY FOR

ALLUME ENERGY PTY LTD and ALLUME ENERGY (UK) LTD

REVISION A1

  1. PRIVACY POLICY
    1. Allume Energy Pty Ltd (ACN 605 671 494) is a business registered in Australia and is committed to keeping your information safe and secure in accordance with the Privacy Act 1988 (Cth) (the Privacy Act) and the Australian Privacy Principles contained therein and any applicable State or Territory law governing your privacy. If you are based in the UK, the controller of your personal information (or “personal data”) is Allume Energy (UK) Ltd, whose registered address is 125 Wood Street, London, United Kingdom, EC2V 7AW. In this Privacy Policy, when we refer to “the Company”, we mean either Allume Energy Pty Ltd or Allume Energy (UK) Ltd.
    2. Please read this Privacy Policy carefully as it contains important information about our use of your personal information, for example if you engage with us directly, if we receive your personal information via a third party (such as an installer), or if we receive your personal information via our SolShare™️ product.
  2. COLLECTION OF PERSONAL INFORMATION
    1. The Company may collect and use the following kinds of personal information:
      1. If you live in a property where SolShare has been installed, your address and energy usage;
      2. If you browse our website or interact with us:
        1. information about your use of the website or online portal (including your IP address; browser type; version and language; operating system; pages viewed while browsing the website or portal; page access times; “cookies”; and referring website address); and
        2. your personal details (including name; phone contact details; address information; email; and payment information).
    2. Your personal information may be collected in a variety of ways, including but not limited to:
      1. when SolShare is installed in the property where you live, the installer of SolShare will upload your address and energy usage to our portal. We will also receive ongoing information about your energy usage from SolShare via its internet connection;
      2. when you access the Company’s website or online portal or otherwise interact with the Company, including by visiting our offices;
      3. when you apply for a job or provide us services (including as an employee or contractor); and
      4. when the Company otherwise provides products and/or services to you.
  3. USE AND DISCLOSURE OF PERSONAL INFORMATION
    1. The Company may use your personal information for the following:
      1. providing the services. This includes supplying the SolShare product as well as any other products and/or services, communicating with and receiving information from third party providers, and collecting payments from you; 
      2. website and online portal access. This includes enabling the functioning of and your access to the website and online portal, measuring usage and traffic statistics to the website and online portal;
      3. communicating with you. This includes sending you marketing communications, reaching out regarding your use of the products and/or services, handling any comments, complaints or enquiries from you, and to administer rewards, surveys, competitions or other promotional activities or events conducted, sponsored or managed by us or our business partners;
      4. internal business practices. This includes improving our goods and services; and
      5. recruitment. This includes considering you for a job with us (whether as an employee or contractor) or in the context of other relationships with us.
    2. The Company may disclose your personal information in the following circumstances:
      1. to the system owner (usually the freeholder, housing provider, body corporate, or government body that manages or controls you building), and their representative and agents;
      2. to resellers or other providers of our SolShare product, including the SolShare installer;
      3. to other companies in our group;
      4. to third parties that provide goods and services to us (including website and data hosting providers, payment system operators and HR service providers) and to our professional advisers and agents (including accountants, insurers, lawyers and auditors);
      5. to any third parties to whom you have directed or permitted us to disclose your personal information (e.g. referees);
      6. in the event that we or our assets may be acquired or considered for acquisition by a third party, to that third party and its advisors;
      7. to third parties that require the information for law enforcement purposes or to prevent a serious threat to public safety; and
      8. otherwise as permitted or required by law.
    3. The Company may also use your personal information to protect the copyright, trademarks, or other intellectual property or legal rights, property or safety of the Company, the Website, and its customers or third parties.
  4. LAWFUL BASIS UNDER UK LAW
    1. If the processing of your personal data is subject to UK data protection law, , we need a lawful basis to process your personal information. We generally rely on the ‘legitimate interests’ basis, as we have a legitimate interest in:
      1. Providing our services, in particular SolShare, to our customers and their end-users;  
      2. Improving and developing the services that we offer, including understanding how they are used;
      3. Promoting our services; and
      4. Protecting the Company, and operating our business effectively.
    2. However, there will also be circumstances where we ask for your specific consent to process your personal information, or where it is necessary to process your personal information to comply with UK law.  
  5. RETENTION
    1. The Company will take commercially reasonable steps to destroy or permanently de-identify personal information if it is no longer needed for the purposes of providing our Services to you and where the Company is not required to retain that information by law.
  6. ACCESS AND CORRECTION
    1. We request that you advise the Company of changes to your personal information that you have provided to the Company as it is essential that your personal information is accurate, complete, and up-to-date in order for the Company to provide Services to you.
    2. By request, you may contact the Company and ask to know what sort of personal information is held about you, for what purposes, and how it is collected, held, used and disclosed.
    3. By request, you may access your personal information by contacting the Company at privacy@allumeenergy.com. Where permitted by law, the Company reserves the right to charge a reasonable administration fee for this access. No fee will be charged in the UK.
    4. If you are in the UK, you also have the right to ask for your personal information to be deleted, or object to it being used for certain purposes.
    5. The Company may consider that there is a sound reason under the Privacy Act, Freedom of Information Act or other relevant law, including UK data protection law, to refuse your request.
  7. IDENTIFIERS AND ANONYMITY
    1. The Company retains, collects and maintains your personal information for statistical analysis purposes (whether for commercial or non-commercial purposes). The Company may share, distribute and/or transfer information which you have provided to the Company to third parties, after that information has been de-identified.
  8. SENSITIVE INFORMATION
    1. Sensitive information is defined in the Privacy Act and under UK data protection law to include information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.
    2. Sensitive information will be used by the Company only:
      1. for the primary purpose for which it was obtained;
      2. for a secondary purpose that is directly related to the primary purpose;
      3. with your consent; or
      4. where required or authorised by law.
    3. In the UK, we will generally only use sensitive information where we have your explicit consent, or where required by law.
  9. TRANS-BORDER DATA FLOWS
    1. The Company may use cloud services, and as such, its servers may be located in Australia or overseas. Your personal information may be transferred and stored in Australia and other foreign jurisdictions which the cloud services may direct the data to be stored.
    2. In addition to the above, the Company will transfer personal information to someone who is in a foreign country where:
      1. the Company reasonably believes that the recipient of the information is subject to a law, binding scheme or contract which effectively upholds principles for fair handling of the information that are substantially similar to the Australian Privacy Principles;
      2. the individual consents to the transfer;
      3. the transfer is necessary for the performance of a contract between you and the Company, or for the implementation of pre-contractual measures taken in response to your request;
      4. the transfer is necessary for the conclusion or performance of a contract concluded in your interest between the Company and a third party;
      5. all of the following apply:
        1. the transfer is for your benefit;
        2. it is impracticable to obtain your consent to that transfer; and
        3. if it were practicable to obtain such consent, you would be likely to give it; or
      6. the Company has taken reasonable steps to ensure that the information which it has transferred will not be held, used or disclosed by the recipient of the information inconsistently with the Australian Privacy Principles.
    3. Where personal information is transferred outside the UK (including to Australia), the Company will take steps to meet the requirements of UK data protection law. This will generally mean putting in place appropriate safeguards (such as an International Data Transfer Agreement) with the recipient. Please contact us if you would like more information about these safeguards.  
  10. COMPLAINTS
    1. As a valuable customer, if you have any complaints in relation to this Privacy Policy or privacy practice, please feel free to contact the Company via privacy@allumeenergy.com.
    2. A complaint should identify whether it is about:
      1. the collection of personal information;
      2. the use of personal information;
      3. the disclosure of personal information;
      4. the security or storage of personal information;
      5. the accuracy of personal information;
      6. a refusal to give access to or provide about their personal information; or
      7. a refusal to change or delete personal information.
    3. The Company values your opinions and takes complaints very seriously. Upon receiving written notice of your complaint about privacy, the Company will respond in a timely manner to advise you of the outcome following its enquiring into the same. You will also be invited to respond to its outcome. If a response is received, the Company will assess your response and advise if it has changed its view. If you are unsatisfied with the final outcome, the Company will advise further options including, if appropriate, making a complaint with the Office of the Australian Information Commissioner. If you are based in the UK, you have a right to complain to the UK Information Commissioner’s Office (ICO) at any point.
  11. OPTING-OUT OF DIRECT MARKETING
    1. The Company aims to give you a highly personalised experience when using the Website and the Services. In order to do so, the Company may use your personal information to send you advertisements to your email address. If you decide you do not want to receive these emails containing advertisements, you can request to unsubscribe from the mailing list by clicking ‘Unsubscribe’ at the bottom of the email.
  12. COOKIES
    1. The Company uses cookies, web beacons and measurement software (the Cookies) on the Website and our online portals to:
      1. store details about your use of the Website to provide you with a personalised experience tailored to you, for example remembering your preferences and greeting you by name;
      2. analyse Website traffic, trends and reporting statistics to improve the Website and our services;
      3. provide you with targeted marketing communications; and
      4. provide you with relevant advertisements when you visit the Website through third party services, such as Google Ads.
    2. You may reject or delete the use of Cookies through the settings on your browser or mobile settings.
  13. THIRD PARTY SITES
    1. The Website may from time to time have links to other websites not owned or controlled by the Company. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that the Company is not responsible for the privacy practises of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information.
  14. AUSTRALIAN USER SPECIFIC PROVISIONS
    1. This section 14 does not apply to UK users. If your personal information is processed by our UK Company, you have rights under the UK General Data Protection Regulation. This Privacy Policy is non-contractual, and does not affect your statutory rights.
    2. Waivers
      1. In limited circumstances, the Company may allow you to waive application of this Privacy Policy. A waiver of this Privacy Policy must be in writing and signed by the Company. The Company anticipates that the waiver of this Privacy Policy would only be in exceptional circumstances, and the Company encourages that you consider the circumstances leading to the waiver request prior to submitting such a request.
    3. Governing Law & Jurisdiction
      1. This Privacy Policy is governed by the laws of Victoria, Australia. In the event of any dispute arising out of or in connection with this Privacy Policy, you agree that the exclusive venue for resolving any dispute shall be Melbourne, Victoria, Australia.
  15. VARIATION TO THIS PRIVACY POLICY
    1. This Privacy Policy is available online via www.allumeenergy.com.au.
    2. The Company reserves the right to modify or amend this Privacy Policy at any time, for any reason, and without any notice, by posting a revised version on its website. Any changes to this Privacy Policy will become effective when the Company posts the revised Privacy Policy on the website. If you are based in Australia, your use of the website following these changes means that you accept the revised Privacy Policy.
    3. This policy was last modified on 18 November 2020.
  16. CONTACT
    1. Please contact the Company if you have any questions regarding this Privacy Policy.
      Email: privacy@allumeenergy.com