(Version 1, 26th May 2020)
| A. About Us | |
| Welcome | Thank you for choosing Tickd.If you need to get in touch with us, please use any contact method on the Tickd Website, or contact us by email at info@tickd.co.uk. |
| About Tickd | This document is published by Tickd Ltd, referred to as “Tickd, we, us or our” in this document.We are a company registered in England and Wales.Our company registration number is 11940271.Our registered office is at Water Court, 116-118 Canal Street, Nottingham, England, NG1 7HF.Tickd is the “controller” or “data controller” with respect to the personal data of the data subjects identified in this policy. |
| About This Document | This document sets out the data privacy policy of Tickd with respect to the personal data of customers of the Tickd Website (the “Tick Data Protection Policy” or “policy”).This is Version 1 of our policy dated 11th May 2020.This policy covers the personal data relating to our customers who use the Tickd Website to obtain comparison quotes for supplies of products and services, including visitors and those who register for an account with us.THIS DOCUMENT IS NOT INTENDED TO CREATE ANY CONTRACTUAL OBLIGATIONS. |
| About the Tickd Website | The “Tickd Website” is a website at http://www.tickd.co.uk that enables you to obtain comparison quotes from suppliers of products and services who have partnered with the Tickd Website, andIf you register for an account with the Tickd Website, you can make an offer to your chosen partner supplier to enter into a supply contract with them, and see details of your supply contracts if an integration has been set up with the partner supplier.At the date of this document, the Tickd Website is only for supplies of products and services to customers in England, Wales, and Scotland. We are not making any offer or promotion outside of those countries. |
| The Laws We Comply With | When we refer to the “personal data protection laws”, we mean any laws of England and Wales that govern the processing of data relating to individuals.At the date of this document, these are in particular the following.The General Data Protection Regulation of the European Union (the “GDPR”) as supplemented by the Data Protection Act 2018. See: https://ico.org.uk/for-organisations/guide-to-data-protection/ The Privacy and Electronic Communications (EC Directive) Regulations 2003See : https://ico.org.uk/for-organisations/guide-to-pecr/what-are-pecr/ When we refer to “personal data”, this has the general meaning in the data protection laws, and in this policy means personal data concerning the categories of data subjects identified in this policy the processing of which is regulated by the personal data protection laws. |
| Our Data Protection Officer | We do not have a data protection officer appointed at the date of this document, but will update this section when we do. |
| Our Regulator | Our local regulator for the purposes of the personal data protection laws is the Information Commissioner for England and Wales.See https://ico.org.uk/ |
| B. About Our Data Subjects | |
| Scope | This section sets out the categories of persons who are our data subjects for the purposes of this policy.When we refer to “you” or “your” in these terms, we mean the individual who is (or is connected with) our customer, who is a data subject for any personal data of which we are controller.NOTE THAT THE PERSONAL DATA PROTECTION LAWS DO NOT PROTECT THE PROCESSING OF COMPANY DATA, SO THAT THIS POLICY DOES NOT APPLY TO THE SAME : BUT IN PRACTICE WE TREAT CORPORATE AND NON-CORPORATE DATA THE SAME. |
| Business Customers | At the date of this document, the Tickd Website is only for use by businesses, organisations other persons who are seeking to procure products and services for their own use and consumption, solely for business or other non-domestic use and purposes.Accordingly our data subjects will be our website customers, where they are individuals, sole traders, partners in a legal partnership, unincorporated associations, individual trustees, or other non-corporate legal entities.In addition, our data subjects may be individuals who are recorded as the representatives or contacts for our customers, where the personal data protection laws govern the processing of such contact information.In addition, our data subjects may be individuals who are living at any premises where any products or services are to be supplied, who are using or reliant on those products or services. |
| Domestic Customers | The Tickd Website is not yet intended for use by consumers in obtaining quotes products and services wholly or partly for domestic use.When we do extend the Tickd Website for this purpose, then our data subjects will include such consumers and their contacts. |
| Intermediaries | The Tickd Website is not yet intended for and does not support use by brokers, agents or other intermediaries.When we do extend the Tickd Website for this purpose, then our data subjects for such persons will be the same as for our business customers above. |
| C. About Your Personal Data | |
| This section sets out the categories of your personal data that we process.It also sets out additional information about how use and disclose that personal data and how long we hold it for. | |
| NAME | |
| Data | Your name.This may include or comprise your business name or partnership name. |
| How we obtain it | From you through input into the Tickd Website. |
| Usage and Purposes | To identify our customers and their representatives.To manage our customer’s accounts, log-in details.To provide our services to you. |
| Legal Basis | Principally, the legal basis is to perform the contract with you for the provision of your online account in the Tickd Website, or to take steps at your request prior to entering into a contract.We also have a legitimate interest in knowing who our customer is (for contract and anti-money laundering purposes) and who their representatives are (for agency purposes). |
| Disclosures to other controllers | To a credit reference agency.To a partner supplier our customer is seeking to enter into a supply contract with. |
| Our Sub-Processors | Our Tickd Website software and hosting provider.Third party information verification and customer authentication services that we use. |
| Retention and Deletion | For the duration of your account with us.For 7 years after the end of your last interaction with us, or if later, after the end of your account with us, for evidential and accounting purposes. |
| CONTACT DETAILS | |
| Data | Your contact details.This may include physical address information, e-mail addresses, telephone numbers, and messaging service contact details. |
| How we obtain it | From you through input into the Tickd Website. |
| Usage and Purposes | To authenticate our customers and their representatives.To send messages to our customers and their representatives relating to or arising in the course of their use of the Tickd Website, their account on the website, or any services provided by us.This may include messages concerning supply contracts our customer is offering to enter into with a partner supplier.This may include messages advising of expiry and renewal of those supply contracts.We may also use these details in future for direct marketing purposes, but this will only be in accordance with the personal data protection laws and consents will be obtained as required. |
| Legal Basis | Principally, the legal basis is to perform the contract with you for the provision of your online account in the Tickd Website, or to take steps at your request prior to entering into a contract.We also have a legitimate interest in knowing who our customer is (for contract and anti-money laundering purposes) and who their representatives are (for agency purposes). |
| Disclosures to other controllers | To a credit reference agency.To a partner supplier our customer is seeling to enter into a supply contract with. |
| Our Sub-Processors | Our Tickd Website software and hosting provider.Third party information verification and customer authenticaion services that we use. |
| Retention and Deletion | For the duration of your account with us.For 7 years after the end of your last interaction with us, for evidential and accounts purposes. |
| WEBSITE USAGE INFORMATION | |
| Data | Details of your visits to the Tickd Website.This may include when you visited, the IP address you visited from, browser information, your location in the globe, the pages you visited, the parts of the pages you viewed, and server session information concerning any processes you are undertaking through our website. |
| How we obtain it | From cookies and other technologies identified in our cookies policy, which record information about your visits and obtain information from your web browser. |
| Usage and Purposes | To monitor trends.To count unique users.To monitor correct usage of the Tickd Website.To improve the design of the Tickd Website.To monitor for problems with the Tickd Website.To provide our website services.To maintain security of the Tickd Website.To improve the Tickd Website. |
| Legal Basis | Principally, the legal basis is to perform the contract with you for the provision of your online account in the Tickd Website, or to take steps at your request prior to entering into a contract.We also have a legitimate interest in that in operating a website visited by the public we need to ensure that the website is useful, functioning correctly and that there are no security risks.Some of this information you may be able to prevent where we provide you with a cookies control dashboard on the Tickd Website. |
| Disclosures to other controllers | To a data analytics provider to provide data analytics services, as may be further detailed in our cookies policy. |
| Our Sub-Processors | Our Tickd Website software and hosting provider. |
| Retention and Deletion | We will normally anonymise this data if we do not need it to be linked with you for the usage and purposes above.If we anonymise it, then we will retain it indefinitely.Otherwise, we may retain it for 2 years after your last visit to our website. |
| ACCOUNT INFORMATION | |
| Data | Your log-in details, but not passwords.Account access and activity history. |
| How we obtain it | From you through forms in the Tickd Website.May also be generated by our systems. |
| Usage and Purposes | To provide online accounts to our customers.To maintain security of those online accounts.To monitor usage (including to detect unauthorised access) to those online accounts.To improve our software and services. |
| Legal Basis | Principally, the legal basis is to perform the contract with you for the provision of your online account in the Tickd Website, or to take steps at your request prior to entering into a contract.We also have a legitimate interest in that in operating a website visited by the public we need to ensure that the website is useful, functioning correctly and that there are no security risks. |
| Disclosures to other controllers | None |
| Our Sub-Processors | Our Tickd Website software and hosting provider. |
| Retention and Deletion | Log-In details are deleted on termination of your account.Access records are retained for the duration of your account with us, and for 7 years after the end of your last interaction with us, for evidential and accounts purposes. |
| PERSONAL INFORMATION | |
| Data | Information that is personal to you.This may include your age and communications and correspondence between you and us (including telephone, email or web-chat conversations). |
| How we obtain it | From you through input into the Tickd Website. |
| Usage and Purposes | To provide quotes to you in the Tickd Website.To provide information to the partner supplier with respect to a supply contract you have offered to enter into with them.With respect to Priority Services Register information we use this only to pass through to an energy supplier where this is required for the purposes of their supply contract with you. |
| Legal Basis | Principally, the legal basis is your consent through inputting such information into the Tickd Website It may also be to the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent. |
| Retention and Deletion | We retain the data for duration of your account with us, and for 7 years after the end of your last interaction with us, for evidential and accounts purposes. |
| CREDIT SCORE INFORMATION | |
| Data | A credit score provided by a credit reference agency that we use; currently ‘Experian‘.Any associated supporting information supplied by the credit reference agency that informed that credit score. |
| How we obtain it | From a credit reference agency through a networked integration with the Tickd Website. |
| Usage and Purposes | To determine what quotes to provide you for products and services from our partner suppliers, based on the rules our partner supplier’s have given us. |
| Legal Basis | Principally, the legal basis is to perform the Tickd Website service you have requested, which is to provide quotes from partner suppliers. Those quotes are dependent on your submitting to a credit check.Our partner suppliers have a legitimate interest understanding your credit score before a quote can be provided, as they need minimise bad debt. |
| Disclosures to other controllers | To the partner supplier with whom our customer is seeking to enter into a supply contract, to enable them to decide whether to enter into that supply contract and whether to impose conditions (such as pre-payment meter). |
| Our Sub-Processors | Our Tickd Website software and hosting provider. |
| Retention and Deletion | We retain the credit score number for the duration of your account with us, and for 7 years after the end of your last interaction with us, for evidential and accounts purposes. |
| SUPPLY ADDRESS INFORMATION | |
| Data | Details of the sites, premises and other addresses where the customer wishes any products or services to be delivered or provided. |
| How we obtain it | From you through input into the Tickd Website.From a third party information verification service. |
| Usage and Purposes | To verify the information against industry records.To provide quotes to you from our partner suppliers.To populate a supply contract document of a partner supplier which is presented to you to make an offer on.To carry out the above on future occasions on renewals and new quotes. |
| Legal Basis | Principally, the legal basis is to perform the Tickd Website service you have requested, which is to provide quotes from partner suppliers and to facilitate your contracting with a chosen partner supplier. |
| Disclosures to other controllers | To a partner supplier our customer is seeking to enter into a supply contract with for the purposes of that supply contract. |
| Our Sub-Processors | Our Tickd Website software and hosting provider.Third party address verification services. |
| Retention and Deletion | For the duration of your account with us.For 7 years after the end of your last interaction with us, for evidential and accounts purposes. |
| METER DETAILS | |
| Data | Where the products and services are an electricity or gas supply, details of the metering equipment and logical meter supply points at the supply address, including MPAN and MPRN, meter serial numbers, and meter registers. |
| How we obtain it | From you through input into the Tickd Website.From a third-party information verification service. |
| Usage and Purposes | To verify the information against industry records.To provide quotes to you from our partner suppliers.To populate a supply contract document with a partner supplier.To carry out the above on future occasions on renewals and new quotes. |
| Legal Basis | Principally, the legal basis is to perform the Tickd Website service you have requested, which is to provide quotes from partner suppliers and to facilitate your contracting with a chosen partner supplier. |
| Disclosures to other controllers | To a partner supplier our customer is seeking to enter into a supply contract with for the purposes of performance of that supply contract. |
| Our Sub-Processors | Our Tickd Website software and hosting provider.Third party meter verification services. |
| Retention and Deletion | For the duration of your account with us.For 7 years after the end of your last interaction with us, for evidential and accounts purposes. |
| QUOTE INFORMATION | |
| Data | Details of each quote which is provided to you by Tickd, including quotes which are disqualified based on the credit score.Quote details include contract duration, scope of products and services, prices and rates, and delivery information, |
| How we obtain it | Most of the data is obtained from our partner suppliers, through integrations with their CRM systems that provide the range of quotes we are able to offer to you.Some data is from you through input into the Tickd Website. |
| Usage and Purposes | To maintain a record of the quotes provided to you and why.To enable you to select a quote.To pass the selected quote information to the offer journey in the Tickd Website to produce a supply contract as detailed further below. |
| Legal Basis | Principally, the legal basis is to perform the Tickd Website service you have requested, which is to provide quotes from partner suppliers and to facilitate your contracting with a chosen partner supplier. |
| Disclosures to other controllers | To a partner supplier our customer is seeking to enter into a supply contract with for the purposes of performance of that supply contract.This is limited to their quote which you have decided to proceed with. |
| Our Sub-Processors | Our Tickd Website software and hosting provider. |
| Retention and Deletion | For the duration of your account with us.For 7 years after the end of your last interaction with us, for evidential and accounts purposes. |
| OFFER INFORMATION | |
| Data | Data concerning the quote you have decided to proceed with.Other data you have provided as noted above.The terms of the supply contract you and the partner supplier are proposing to enter into. Evidences of ticked boxes, clicked buttons, signature in an online service (such as DocuSign) and any other evidence that you are making an offer to a partner supplier. |
| How we obtain it | Most of the data is obtained from the other data sources above.The supply contract template and partner supplier terms and conditions are provided by the partner supplier on a confidential basis.The Tickd Website then combines the two to populate the supply contract template. |
| Usage and Purposes | To populate your chosen partner supplier’s supply contract form with the details of the quote you have chosen to proceed with.To maintain evidence of your intention to make an offer to the partner supplier.To upload to the partner supplier’s contract signature system such as DocuSign.To upload to the partner supplier’s CRM system the set of data relating to you that represents the supply contact terms, including the quote information and contract form, to enable the partner supplier to accept and on-board the sale with you and process it further as controller in their own systems. |
| Legal Basis | Principally, the legal basis is to perform the Tickd Website service you have requested, which is to provide quotes from partner suppliers and to facilitate your contracting with a chosen partner supplier. |
| Disclosures to other controllers | To a partner supplier our customer is seeking to enter into a supply contract with for the purposes of performance of that supply contract.Where the partner supplier uses DocuSign (or similar) for a contract signing process, then DocuSign is the partner supplier’s sub-processor, and in providing the supply contract document to DocuSign (or equivalent) we are providing it in effect to the partner supplier.This is limited to their quote which you have decided to proceed with. |
| Our Sub-Processors | Our Tickd Website software and hosting provider. |
| Retention and Deletion | For the duration of your account with us. For 7 years after the end of your last interaction with us, for evidential and accounts purposes. |
| SUPPLY CONTRACT CRM INFORMATION | |
| Data | Information concerning your supply contracts with your chosen partner suppliers, where such information is made accessible to the Tickd Website and your online account by the partner supplier.These may include current and historical supply contracts.The range of data will depend on the integration and what the partner supplier has agreed to supply and will be apparent from your online account with the Tickd Website. It may include: your account number, contact details held by the partner supplier, price and tariff information, meter reading information, bills, payments and statement information, account balance information, general documents that your partner supplier shares with you, your supply contract documents, priority services registers, contract duration, and any business process tracking information.For example, we may subscribe to events in the partner supplier’s systems that will inform us of any events and information relating to your supply contract, such as electricity and gas change of supplier related events |
| How we obtain it | A network connection between the Tickd Website and the partner supplier’s contract management systems. |
| Usage and Purposes | To provide you with updates as to the progress and status of your supply contract with the partner supplier through your Tickd account.To provide general information to you about your supply contracts, that would otherwise be available in any customer portal provided by a partner supplier in their own systems.To obtain historical information (such as consumption and usage information) which may be used to inform and construct future quotes for you (including renewal quotes) in the Tickd Website).To advise you of when your supply contract may expire and to send you renewal reminders.To identify when we may be due a commission payment from the partner supplier you have contracted with. |
| Legal Basis | Principally the legal basis is to perform the contract with you for the provision of your online account in the Tickd Website.In addition, we consider we have a legitimate interest in processing contract expiry and metering information to perform what the Tickd Website is in the market to do, which is provide you with reliable quotes and renewal advisory information.However, you can ask us to stop processing this information at any time, in which case we will disable the Tickd Website features and will not inform you about contract renewals. |
| Disclosures to other controllers | None. |
| Our Sub-Processors | Our Tickd Website software and hosting provider. |
| Retention and Deletion | We do not permanently store this information, and we retrieve it each time you access your account in the Tickd Website and use features in that account to view that information.We may hold a temporary cache of that information, that information is not stored by us in a permanent form outside the time of your session when visiting the Tickd Website.The exception is that we may store contract expiry information and consumption information for renewal advisory communications and future quote journeys you start.We delete this stored information on termination of your online account with us. |
| SUPPLY CONTRACT CUSTOMER INPUT INFORMATION | |
| Data | Meter readings or other usage information concerning any use or consumption of the products and services of a partner supplier which you provided via the Tickd Website. |
| How we obtain it | You provide it through a form in the Tickd Website. |
| Usage and Purposes | To pass through you the partner supplier you have contracted with for the purposes of their supply contract with you. |
| Legal Basis | Principally the legal basis is to perform the contract with you for the provision of your online account in the Tickd Website.We note that you decide when to use this functionality. |
| Disclosures to other controllers | Partner suppliers of the Tickd Website who you have a supply contract with. |
| Our Sub-Processors | Our Tickd Website software and hosting provider. |
| Retention and Deletion | See section ‘Supply Contract CRM Information‘. |
| D. Other Important Information | |
| Basis on which you provide personal data | All personal data which you supply to us is supplied to us on one of the following bases.Voluntarily: You have chosen to provide it to use our Tickd Website and price comparison service; or you have chosen to allow us to receive it from a partner supplier as part of your account with us.Contractual: You need to provide it, or we need to obtain it, in order to provide our Tickd Website and services to you, or in order to enter into a contract with us to use our services or a supply contract with a partner supplier.You are not, at any time, obliged to provide data to us. |
| Credit Checks | In order to provide quotes in the Tickd Website an application is made with a credit reference agency by Tickd to obtain a credit score and credit report for the customer seeking the quote.This happens each time a quote journey is initiated.We use that information in conjunction with rules provided to us by our partner suppliers to decide what quotes to present to you (if any).The credit reference agency we currently use is Experian.A credit reference agency (CRA) is a company that collects personal information from various sources, generates a credit score from that information, and makes the information available to prospective suppliers of products and services to make credit decisions.A CRA search by us will normally return information about you, any person who is jointly seeking the quote with you, and anyone with a financial association with you (e.g. where you have applied elsewhere for a financial agreement with someone else).The CRA will provide to us any publicly held data (including electoral roll) and any credit performance data they hold for sharing with businesses that subscribe to their credit reference services.When a search is made, a “footprint” of that search is place on your credit report held by the CRA and the report of any joint applicant for a quote, and any financial associate, even if you do not proceed with any quote; but this search should not affect any ability to gain credit.The CRA is a controller in their own right, and any copy of your data sent to them, or data about you generated by them, is not covered by this privacy policy but by their own privacy policy.Experian’s policy can be found here: https://www.experian.co.uk/legal/crain/You can contact Experian if you wish to obtain a copy of your credit report.Experian, Consumer Help Service, PO Box 8000, Nottingham NG80 7WF or call 0844 4818000 or log on to www.experian.co.uk. |
| Automated Decision Making | Automated decision-making is used within the Tickd Website.It consists of using your credit score to decide whether to provide our customer with a quote from a partner supplier and what quote to provided.We establish with our partner suppliers a range of quotes which we will show to our customer according to what the credit score is.For instance, prices may be higher or lower depending on the credit score, or no quote at all may be provided, depending on the rule set by our partner supplier. |
| Partner Suppliers and other disclosures | If you choose to proceed with a quote and make an offer to a partner supplier to enter into a supply contract, then any copy of your data we provide to them will be held by them as data controller and subject to their own privacy policy, and not subject to this policy. You should contact the partner supplier directly for further details.In the same manner, if we provide a copy of your personal data to any other controller, then it will be held by them subject to their published privacy policy and not subject to this policy. |
| Sub-Processing | Our Tickd Website and its databases are provided and hosted for us by ENSEK Ltd, which is the primary place where your personal data is held.We also use Microsoft 365 cloud based products for back-office business management which may also be used incidentally to store ad-hoc parts of your personal data in documents, spreadsheets and emails.We also use third parties to verify your address and meter details with industry databases. |
| Transfers outside the UK | Our systems (including the Tickd Website and Microsoft 365) are hosted either in the UK or in the European Union (currently the Republic of Ireland).Accordingly your personal data will be transferred out of the UK for this purpose. |
| Security Measures | We are obliged by the personal data protection laws to implement appropriate technical and organisational measures concerning your data and our systems to ensure a level of security appropriate to the risk to you and your data.We undertake such measures and will be updating this policy in due course with further information. |
| Our Right to Change This Policy | We shall be entitled to vary and amend this policy at any time and from time to time, by updating it in the Tickd Website, or by email to you, or by general notice placed in your account home page. |
| E. About Your Legal Rights | |
| Introduction | This section summaries your key rights under the personal data protection laws, subject to any conditions and rules set out in those laws.See also: https://ico.org.uk/your-data-matters/ |
| Right to withdraw consent | If we process your data for a particular purpose (e.g. direct marketing) based only on a consent obtained from you, you can withdraw that consent at any time, and we must then stop that kind of processing. |
| Right to Complain | You have the right to lodge a complaint with a supervisory authority.Our local supervisory authority is the Information Commissioner for England and Wales.See: https://ico.org.uk/make-a-complaint/ |
| Right to Access | You have a right of access to your personal data being processed by us (known as a subject access request).This includes a copy of your personal data that we hold.We may make a reasonable administrative fee for more than one copy. |
| Right to Rectification | You can ask us to rectify your data if it is inaccurate.You can ask us to complete any data which you think is not complete, by supplying supplementary data. |
| Right to Erasure (to be forgotten) | You can ask us to erase your data.There must be a good reason, such as: we don’t need the data anymore; you withdrew a consent; you object to the processing and we don’t have legitimate grounds to keep processing; we are processing unlawfully; to comply with a law.There are also circumstances when we can refuse, such as: we are obliged by law to hold and process that data (such as for tax records); or we need to hold the data as evidence for the establishment, exercise or defence of legal claims you or our customer might bring against us. |
| Right to restrict processing | You have the right to ask us to restrict the processing of your data in some way, such as the examples below.If you think the data is inaccurate and you want us to check it.If you think we are being unlawful, and want to look into this before we erase your data.You want us to hold on to your data in connection with legal claims.You have otherwise objected to our processing, and want us to pause processing until we have justified it to you. |
| Right to data portability | You can ask for a copy of your data in an industry recognised data format if you need this to move your data to another controller.You can also ask to have your data transferred directly to someone else if this is technically feasible.We reserve the right to make a reasonable charge for the above work (unless the personal data protection laws prohibit the making of such a charge). |
| Right to object to processing | You have a general right to object to the processing of your data where we are processing it for reasons other than consent, legal obligation, or contract. However, you must provide grounds for your objection, that are related to your particular situation. We must then stop, unless we can provide a compelling reason to continue that justifiably overrides your grounds.As noted above, you also have right to object to and withdraw your consent to any processing for direct marketing purposes and any associated profiling. |
| Right to stop automated decision making | You have the right to stop any automated decision making we carry out.However, our partner suppliers require Tickd to obtain credit scores before they provide quotes, so if you do stop such processing, we will not be able to provide our price comparison services to you, and you should stop using the Tickd Website to obtain further quotes from our partner suppliers. |
End – Tickd Privacy Policy |