Privacy Policy

Purpose and scope of this Policy

This Privacy Policy explains how Holborn Energy Ltd collects, uses, stores and protects personal data in accordance with the UK GDPR, the Data Protection Act 2018 and other applicable UK data protection laws.

This policy applies to users of our website and to individuals whose personal data we process in the course of our business, including business contacts, prospective customers, customer representatives, brokers, suppliers, consultants and other people who contact or interact with us.

Most personal data we process relates to people acting in a business capacity, such as directors, employees, consultants, brokers, customer contacts, supplier contacts and professional advisers.

Data Controller

The data controller responsible for the processing of your personal data is:

Holborn Energy Ltd.
4th Floor, Regent House
50 Frederick Street
Birmingham
B1 3HR

Personal Data We Collect

WDepending on your relationship with us, we may collect and use the following types of personal data:

  1. Identity and contact data: name, business name, role or job title, business email address, telephone number and postal address.
  2. Enquiry and correspondence data: information you provide when contacting us, including the content of your enquiry and any follow-up correspondence.
  3. Customer, broker, supplier and partner data: business contact details, contractual information, account administration records, site or supply-related contact information and relationship management records.
  4. Website and technical data: IP address, browser type, device information, pages visited, access times, server logs and similar technical information.
  5. Cookie and analytics data: information collected through cookies or similar technologies, where applicable.
  6. Compliance and regulatory data: records we need to keep to meet legal, regulatory, accounting, audit or industry obligations.

We do not normally collect special category personal data through our website or as part of ordinary business-to-business energy supply activities. Please do not provide special category personal data unless we specifically request it.

How we collect personal data

We usually collect personal data directly from you, for example when you contact us, request information, correspond with us, use our website, or act on behalf of a customer, broker, supplier or business partner.

We may also receive business contact details from your employer, broker, consultant, introducer, supplier, industry body, public register or another organisation involved in a business energy supply relationship.

Purposes and lawful bases

We use personal data only where we have a lawful basis to do so. The main purposes and lawful bases are set out below.

PurposePersonal data usedLawful basis
Operating and securing our websiteIP address, device and browser information, server logs, basic usage information.Legitimate interests: running a secure and functional website.
Responding to enquiriesName, business name, role, contact details, enquiry content and correspondence.Legitimate interests: responding to business enquiries and managing relationships.
Providing quotes, onboarding or administering business supply arrangementsBusiness contact details, site or supply-related contact information, correspondence and contractual information.Contract or steps before entering into a contract; legitimate interests for business administration.
Meeting legal, regulatory and industry obligationsRelevant contact, account, correspondence, transaction, compliance and regulatory records.Legal obligation.
Managing suppliers, brokers and business partnersBusiness contact details, role, correspondence, contract and payment-related information.Contract; legitimate interests.
Maintaining business records and protecting our legal positionRelevant correspondence, contracts, notices, account records and related business records.Legitimate interests; legal obligation where records must be kept by law.
Using optional analytics or non-essential cookiesCookie identifiers, device information and website usage data.Consent, where required.

Legitimate Interests

Where we rely on legitimate interests, our interests include operating and securing our website, responding to business enquiries, managing customer, broker and supplier relationships, maintaining business records, improving our services, and protecting our legal and commercial position. We only rely on legitimate interests where we have considered that our interests are not overridden by your rights and freedoms.

Cookies and similar technologies

Our website may use essential cookies that are necessary for the website to function. We may also use non-essential cookies, such as analytics cookies, where you have consented to them.

You can manage cookie preferences through your browser settings and, where provided, our cookie banner or cookie preference tool. If we use non-essential cookies, we will provide appropriate information and controls before those cookies are set, unless the law permits otherwise.

Who we share personal data with

We may share personal data where necessary with:

  1. IT, hosting, website, email and business support providers;
  2. professional advisers, including legal, accounting, audit and insurance advisers;
  3. brokers, suppliers, consultants, contractors or business partners involved in providing or administering our services;
  4. energy industry bodies, network operators, regulators, government bodies, law enforcement agencies or courts, where required or appropriate;
  5. another organisation in connection with a business sale, restructuring, merger or similar corporate transaction.

We require service providers to protect personal data and to use it only for the purposes for which it is shared with them.

International transfers

We aim to keep personal data within the UK or other jurisdictions that provide appropriate protection. If we transfer personal data outside the UK, we will ensure appropriate safeguards are in place, such as adequacy regulations, approved contractual clauses, or another lawful transfer mechanism.

Retention

We keep personal data only for as long as necessary for the purposes for which it was collected. In general:

  1. website server logs are kept for a limited period needed for security and troubleshooting;
  2. enquiry records are kept for as long as needed to respond and for reasonable follow-up;
  3. customer, supplier, broker and contractual records are kept for the duration of the relationship and then for the period required for legal, regulatory, accounting, audit or dispute-resolution purposes;
  4. data processed based on consent is kept until consent is withdrawn or the data is no longer needed.

We may retain anonymised information for analysis and reporting where individuals can no longer be identified.

Your Rights

Under GDPR, you have the following rights regarding your personal Subject to applicable legal conditions and exemptions, you may have the right to:

  1. request access to your personal data;
  2. request correction of inaccurate or incomplete personal data;
  3. request deletion of personal data;
  4. request restriction of processing;
  5. object to processing, including processing based on legitimate interests;
  6. request data portability, where applicable;
  7. withdraw consent at any time, where processing is based on consent.

To exercise your rights, please contact informationcompliance@holbornenergy.co.uk. We may need to verify your identity before responding to a request.

Required information

You are not generally required to provide personal data when browsing our website. However, if you contact us, request a quote, enter into a contract, or act as a representative of a customer, supplier, broker or partner, we may need certain personal data to respond, provide services, administer the relationship, or meet legal and regulatory obligations. If required information is not provided, we may be unable to respond or provide the relevant service.

Automated decision-making

We do not use personal data collected through this website to make solely automated decisions that produce legal or similarly significant effects.

Security Measures

We use appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse, alteration or disclosure. These measures are reviewed and updated where appropriate.

Complaints

If you have any questions or concerns about how we use personal data, please contact us first so that we can try to resolve the issue.

Information Compliance Manager
Holborn Energy Ltd.
4th Floor, Regent House
50 Frederick Street
Birmingham
B1 3HR

By e-mail: informationcompliance@holbornenergy.co.uk

You also have the right to complain to the Information Commissioner’s Office, the UK supervisory authority for data protection matters. You may contact the ICO using the details below:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF