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Ripple’s Privacy Policy

Introduction

Ripple respects your privacy and prioritises keeping your data secure. We are committed to being transparent and this privacy policy will inform you how we collect and use your data and tell you about your privacy rights. Please also use the Glossary to understand the meaning of some of the terms used.

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 policy of every website you visit.

Ripple’s Structure, Business and Contact Details

Ripple Energy Limited (“Ripple” “we” “our”) is a private limited company (company number 10565718) incorporated on 16 January 2017 and whose registered office is at Ripple Energy Limited, The Frames, 1 Phipp Street, Unit 2.08, London EC2A 4PS.

Ripple is a platform that enables cooperative ownership of large-scale renewable energy projects. Ripple identifies suitable projects, undertakes due diligence and then brings together households to collectively purchase the project. Ripple then manages the construction and operation of the project.

If you have any questions about this privacy policy or our privacy practices, please contact us by email at dataprotection@ripplenergy.com

How do we collect and use your data

We will only use your data when the law allows us to. Most commonly, we will use your data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

    • We may be required to share your data with the parties set out below for the purposes set out in the table below:

  • External third parties as set out in the Glossary.
  • 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 data in the same way as set out in this privacy policy.

    We require all third parties to respect the security of your data and to treat it in accordance with the law. We do not allow our third-party service providers to use your data for their own purposes and only permit them to process your data for specified purposes and in accordance with our instructions.

    We have set out below, in a table format, a description of how and when we collect your data, the type of data collected from you and why we collect this data.

    Note that we may process your 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 data where more than one ground has been set out below.

    Direct interactions when you:

  • register as a new customer;
  • apply for our products or services;
  • create an account on our website;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion, survey or campaign;
  • give us feedback or contact us;
  • enter information from within the dashboard; or
  • link your consumption data to your Ripple account.
  • switch energy supplier

    • Type of data collected

  • Identity
  • Contact
  • Profile
  • Usage
  • Financial
  • Transactional
  • Marketing and Communications
  • Energy
  • Switching supplier

    • Why do we collect your data

  • When necessary for our legitimate interests
  • Entering into and performance of a contract with you
  • To process and deliver your order including manage payments, fees and charges and collect and recover money owed to us
  • To manage our relationship with you which will include notifying you about changes to our terms or privacy policy and asking you to leave a review or take a survey
  • To deliver views and insights of your generation and consumption data
  • To process your switch with the nominated supplier

    • Automated technologies or interactions.

    As you interact with our website, we will automatically collect data about your equipment, browsing actions and patterns. We collect this data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

    Type of data collected

  • Technical
  • Aggregated

    • Why do we collect your data

    Please see Ripple’s cookie policy for details on the types of cookies used

    Third parties or publicly available sources as set out below:

  • Technical Data from the following parties based both in and outside the EU:
  • analytics providers such as Google;
  • advertising networks; and
  • search information providers.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
  • Identity and Contact Data from data brokers or aggregators.
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register.
  • Energy network operators.
  • Government and local councils.
  • Other energy suppliers and OFGEM.
  • Credit reference agencies.

    • Type of data collected

  • Identity
  • Identity
  • Contact
  • Financial
  • Transactional
  • Technical
  • Profile
  • Usage
  • Energy
  • Marketing and Communications

    • Why do we collect your data

  • When necessary for our legitimate interests (including: i. to study how customers use our products/services, to develop them and grow our business and to inform our marketing strategy; ii. running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise; iii. to define types of customers for our products and services, to keep our website updated and relevant)
  • Entering into and performance of a contract with you
  • To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  • To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
  • To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
  • To make suggestions and recommendations to you about goods or services that may be of interest to you
  • Performance of a contract with you
  • Necessary for our legitimate interests (to recover debts due to us)

    • Marketing

    We strive to provide you with choices regarding certain data uses, particularly around marketing and advertising.

    We may use your Identity, Contact, Technical, Usage and Profile 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.

    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.

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

    You can opt-out of marketing emails at any time by selecting unsubscribe from a Ripple marketing email.

    Where you opt out of receiving these marketing messages, this will not apply to data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

    Data security

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

    We have put in place procedures to deal with any suspected 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 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 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 data, we consider the amount, nature and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure of your data, the purposes for which we process your data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

    Your data protection rights

    You have the right to:

    Request access to your data (commonly known as a “data subject access request”). This enables you to receive a copy of the data we hold about you and to check that we are lawfully processing it.

    Request correction of the 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 data. This enables you to ask us to delete or remove 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 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 data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

    Object to processing of your 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 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 data. This enables you to ask us to suspend the processing of your 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.

    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 data to you or to a third party. We will provide to you, or a third party you have chosen, your 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 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.

    If you would like to exercise any of those rights, please email us at dataprotection@rippleenergy.com. If you have any concerns about how your data is being processed, please contact us and we will do our best to explain our processing and to provide reassurance to you.

    If you are not happy with the way we have handled your data, or would like more information about your rights, you can contact the Information Commissioner’s Office, the UK’s independent authority on data privacy at ico.org.uk.

    Glossary

    External third parties means:

  • Service providers acting as processors who provide IT and system administration services.
  • Technology partners who may have products or services that we consider may be of interest to you and who may contact you if you have given your opt-in consent to receive third party marketing
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

    • Your data can be grouped together as follows:

  • Identity includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact includes billing address, delivery address, email address and telephone numbers. As well as your contact details, contact details of your beneficiaries, if entered, may also be stored.
  • Financial includes bank account and payment card details.
  • Transactional includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical includes internet protocol (IP) address, your login data, 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 this website.
  • Profile includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. Profile data also includes your estimated annual consumption.
  • Usage includes information about how you use our website, products and services.
  • Energy includes details about your energy supplier and account number, generation data from your operating Ripple project, and consumption data. Half hourly consumption data stored if you connect your consumption data from your energy supplier account to your Ripple account via the Ripple dashboard. It is optional and more can be read in the specific Ripple features section of this document.
  • Marketing and Communications includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Aggregated such as statistical or demographic 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 Usage 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 privacy policy.
  • Switching supplier includes details of your fuel type, estimated consumption, selected tariff and payment instructions. This information is passed to your nominated supplier.

    • Ripple Energy Limited

    20 March 2024