Mallusk Enterprise Park, Newtownabbey, BT36 4GN
+44 (0) 2890 777 834
info@sdsenergy.com

Privacy Policy

Effective Date: 2 May 2018

Thank you for your interest in SDS (“SDS”, “we,” or “us”), our website at https://www.sdsenergy.com (“Site”), all related websites, on which a link to this Privacy Policy is displayed, and all other communications with individuals though from written or oral means, such as email or phone in relation to the energy services we provide (“Service”).

This Privacy Policy (“Policy”) describes the information that we gather on or through our Site and Service, how we use and disclose such information, and the steps we take to protect such information. We will not use or share your information with anyone except as described in this Privacy Policy. This Policy is incorporated into, and is subject to, SDS Terms of Service. Capitalized terms used but not defined in this Policy have the meaning given to them in the SDS Terms of Service.

By visiting the Site, or using the Service, you accept the privacy practices described in this Policy.

1       Definitions

“Client” means a paying customer of SDS.

“Client Data“ means personal data, reports, addresses, and other files, folders or documents in electronic form that are stored in relation to the Service.

“Personal Data” means any information relating to an identified or identifiable natural person.

“Public Area” means the area of the Site that can be accessed both by Users and Visitors, without needing to log in.

“Restricted Area” means the area of the Site that can be accessed only by Users, and where access requires logging in.

“User” means an employee, agent, or representative of a Client, who primarily uses the restricted areas of the Site for the purpose of accessing the Service in such capacity.

“Visitor” means an individual other than a User, who uses the public area, but has no access to the restricted areas of the Site or Service.

2       The information we collect

We collect different types of information from or through our Site and Service.

2.1       Our Service

We may collect personally identifiable information about you, such as your full name, phone number, email address, postal address or similar, when you complete any online forms on our Site or receive our Service. We do not send any promotional emails; however, we may send you Service related emails. If you no longer wish to receive these emails, you may opt out of them by following the link to unsubscribe at the foot of the email.

2.2       Cookies And Tracking Technologies

Technologies such as cookies are used by SDS to track visits and clicks on our Site. These technologies may be used in analysing trends, tracking your movements around the Site and to gather demographic information about our user base as a whole. We use cookies to remember users’ settings as well as for authentication and analytics. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our Sites, but your ability to use some features or areas of our Sites may be limited.

We display a notification to each Visitor to show that our Site uses cookies. The notification terms are as follows: “This website stores cookies on your computer. These cookies are used to collect information about how you interact with our website and allow us to remember you. We use this information in order to improve and customise your browsing experience and for analytics and metrics about our visitors both on this website and other media. To find out more about the cookies we use, see our Privacy Policy [https://www.sdsenergy.com/privacy-policy/]”along with the disclaimer, “If you decline, your information won’t be tracked when you visit this website. A single cookie will be used in your browser to remember your preference not to be tracked.” The Visitor is required to opt in by clicking “Accept” or opt out by clicking “Decline”.

3       How we use the information we collect

We use the information that we collect in a variety of ways in providing the Service and operating our business, including the following:

3.1       Operations

We use the information to operate, maintain, enhance and provide all features of the Service, to provide the services and information that you request, to respond to comments and questions and to provide support to users of the Service. We process Client Data in accordance with the directions provided by the applicable Client or User.

3.2       Improvements

We use the information to understand and analyse the usage trends and preferences of our Visitors and Users, to improve the Service, and to develop new products, services, feature, and functionality. Should this purpose require SDS to process Client Data, then the data will only be used in anonymised or aggregated form.

3.3       Communications

We may use a Visitor’s or User’s email address or other information to contact that Visitor or User (i) for administrative purposes such as customer service or (ii) with updates on services and/or events, relating to products and services offered by us and by third parties we work with. You have the ability to opt-out of receiving any unwanted communications as described below under “Your Choices.”

3.4       Cookies and Tracking Technologies

We use automatically collected information and other information collected on the Site through cookies and similar technologies to: (i) personalise our Service, such as remembering a User’s or Visitor’s information so that the User or Visitor will not have to re-enter it during a visit or on subsequent visits; (ii) provide customised advertisements, content, and information; (iii) monitor and analyse the effectiveness of the Site and marketing activities; (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (v) track your entries, submissions, and status in any activities on the Site. You can obtain more information about cookies by visiting http://www.allaboutcookies.org.

3.5       Analytics

We use Google Analytics to measure and evaluate access to and traffic on the Public Area of the Site, and create user navigation reports for our Site administrators. Google operates independently from us and has its own privacy policy, which we strongly suggest you review. Google may use the information collected through Google Analytics to evaluate Users’ and Visitors’ activity on our Site. For more information, see Google Analytics Privacy and Data Sharing.

We take measures to protect the technical information collected by our use of Google Analytics. The data collected will only be used on a need to know basis to resolve technical issues, administer the Site and identify visitor preferences; but in this case, the data will be in non-identifiable form. We do not use any of this information to identify Visitors or Users.

4       To whom we disclose information

Except as described in this Policy, we will not intentionally disclose the Personal Data or Client Data that we collect or store on the Service to third parties without the consent of the applicable Visitor, User or Client. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:

4.1       Unrestricted Information

Any information that you voluntarily choose to include in a Public Area of the Service, such as a public profile page, will be available to any Visitor or User who has access to that content.

4.2       Service Providers

We work with third party service providers who provide website, application development, hosting, maintenance, and other services for us. These third parties may have access to, or process Personal Data or Client Data as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information.

4.3       Non Personally Identifiable Information

We may make certain automatically-collected, aggregated, or otherwise non-personally-identifiable information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our Clients’, Users’ and Visitors’ interests, habits, and usage patterns for certain programs, content, services, and/or functionality available through the Service.

4.4       Law Enforcement, Legal Process and Compliance

We may disclose Personal Data or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a facially valid court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.

We also reserve the right to disclose Personal Data or other information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, or (v) protect our property or other legal rights, enforce our contracts, or protect the rights, property, or safety of others.

4.5       Change of Ownership

Information about Users and Visitors, including Personal Data, may be disclosed and otherwise transferred to an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets and only if the recipient of the User or Visitor Data commits to a Privacy Policy that has terms substantially consistent with this Privacy Policy.

Client Data may be physically or electronically transferred to an acquirer, or successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets, for the sole purpose of continuing the operation of the Service, and only if the recipient of the Client Data commits to a Privacy Policy that has terms substantially consistent with this Privacy Policy.

5       Your choices

5.1       Access, Correction, Deletion

We respect your privacy rights and provide you with reasonable access to the Personal Data that you may have provided through your use of the Services. If you wish to access or amend any other Personal Data we hold about you, or to request that we delete or transfer any information about you that we have obtained, you may contact us via info@sdsenergy.com At your request, we will have any reference to you deleted or blocked in our database.

You may update, correct, or delete your Account information and preferences at any time by accessing your Account settings page on the Site. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

At any time, you may object to the processing of your Personal Data, on legitimate grounds, except if otherwise permitted by applicable law. If you believe your right to privacy granted by applicable data protection laws has been infringed upon, please contact info@sdsenergy.com to report the issue. You also have a right to lodge a complaint with data protection authorities.

5.2       Navigation Information

You may opt out from the collection of navigation information about your visit to the Site by Google Analytics by using the Google Analytics Opt-out feature [https://tools.google.com/dlpage/gaoptout].

5.3       Opting out from Commercial Communications

If you receive commercial emails from us, you may unsubscribe at any time by following the instructions contained within the email or by sending an email to info@sdsenergy.com

Please be aware that if you opt-out of receiving commercial email from us or otherwise modify the nature or frequency of communications you receive from us, it may take up to ten (10) business days for us to process your request.

6       Third-party services

The Site may contain forms to link information to third parties and this is subject to those operators’ policies. This will always be brought to your attention at the time of gathering data and we will encourage you to learn about third parties’ privacy and security policies before providing the information.

6.1       Tracker Plus

Tracker Plus records project related data for and on behalf of our clients and their employees. In these cases, SDS is acting as a Data Processor on behalf of our Clients. For more information, please speak to your employer/the relevant Data Controller.

SDS shall be classed as a Data Controller where deciding the manner in which data is processed when looking to meet our contractual obligations, for example where selecting third party suppliers to support our online systems.

7       Third-party cookies

We allow third parties with which we have a separate agreement to use cookies and other technologies to collect information about your use of the Site. We use third parties such as Google Analytics, Google Tag Manager and Google AdWords; and tools provided by Yahoo, Bing, LinkedIn, Facebook, Twitter for conversion tracking and HubSpot for Customer Relationship Management.

Some or all of these tools may be used to track information about your behaviour on our website depending on your region. For more information or to opt-out, please visit the respective website(s) of these vendors or contact us at info@sdsenergy.com for more information.

We do not share with these third parties any information that would readily identify you (such as email address); however, these third parties may have access to information about your device (such as IP or MAC address). We do not have access to, or control over, the technologies that these third parties may use to collect information about your interests, and the information practices of these third parties are not covered by this Privacy Notice. Other than as discussed in this document, we have no control over these third parties.

We are committed to privacy and current industry initiatives to protect individual rights on the internet. Recent European privacy laws require such third parties to explicitly outline what tracking cookies are used in their applications and why. Again, please visit the respective website(s) of these vendors or contact us at info@sdsenergy.com for more information.

8       The following types of cookies are used in the Site:

As we use the HubSpot tracking code for Customer Relationship Management, we shall provide specific detail as follows:

HubSpot’s tracking code sets the following cookies when a Visitor accesses our site. These cookies fall into two general categories:

  • Essential/necessary cookies: these cookies do not require consent.
  • Consent banner cookies: there are cookies included in the consent banner under GDPR.

Specific cookie names and descriptions are listed below:

 

Essential/necessary cookies

 

__hs_opt_out

This cookie is used by the opt-in privacy policy to remember not to ask the visitor to accept cookies again. This cookie is set when you give visitors the choice to opt out of cookies.

(Expires: 2 years)

 

__hs_do_not_track

This cookie can be set to prevent the tracking code from sending any information to HubSpot. Setting this cookie is different from opting out of cookies, which still allows anonymized information to be sent to HubSpot.

(Expires: 2 years)

 

__hs_testcookie

This cookie is used to test whether the visitor has support for cookies enabled.

(Expires: Session cookie)

 

hs_ab_test

This cookie is used to consistently serve visitors the same version of an A/B test page that they’ve seen before.

(Expires: Session cookie)

 

hs_lang_switcher_choice

This cookie is used to consistently redirect visitors to the language version of a page in the language they’ve selected on this top-level private domain in the past (if such a language version exists).

 

<id>_key

When visiting a password-protected page, this cookie is set so future visits to the page from the same browser do not require login. The cookie name is unique for each password-protected page.  

 

hs-messages-is-open (TTL 30 minutes)

This cookie is used on the visitor UI side so HubSpot can determine/save whether the chat widget is open for future visits. It resets after 30 minutes to re-close the widget after 30 minutes of inactivity

 

hs-messages-hide-welcome-message (TTL 1 day)

 

When you dismiss the welcome message in your messages tool, a cookie is set to prevent it from appearing again for one day.

 

Consent banner cookies

 

__hstc

The main cookie for tracking visitors. It contains the domain, utk (see below), initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session).

(Expires: 2 years)

 

hubspotutk

This cookie is used for to keep track of a visitor’s identity. This cookie is passed to HubSpot on form submission and used when de-duplicating contacts.

(Expires: 10 years)

 

__hssc

This cookie keeps track of sessions. This is used to determine if we should increment the session number and timestamps in the __hstc cookie. It contains the domain, viewCount (increments each pageView in a session), and session start timestamp.

(Expires: 30 min)

 

__hssrc

Whenever HubSpot changes the session cookie, this cookie is also set. We set it to 1 and use it to determine if the visitor has restarted their browser. If this cookie does not exist when we manage cookies, we assume it is a new session.

(Expires: None. Session cookie)

 

messagesUtk

This cookie is used to recognize visitors who chat with you via the messages tool. If the visitor leaves your site before they’re added as a contact, they will have this cookie associated with their browser. If you have a history of chatting with a visitor and they return to your site later in the same cookied browser, the messages tool will load your conversation history with that visitor.

 

If the Visitor is logged in to HubSpot, HubSpot will set additional authentication cookies. You can see a complete list of cookies set by HubSpot’s app here [https://knowledge.hubspot.com/articles/kcs_article/account/hubspot-cookie-security-and-privacy].

9       Employees and applicants

SDS is the data controller for the information you provide during the process unless otherwise stated. If you have any queries about the process or how we handle your information, please contact us on the details at the bottom of the page.

What will we do with the information you provide to us?

All information you provide during the application process will only be used for the purpose of progressing your application, or to fulfil legal or regulatory requirements if necessary.

We will not share any of the information you provide during SDS’s internal recruitment process with any third parties for marketing purposes. Data sent electronically or processed beyond the initial application will be stored within the European Economic Area by our third-party processors – all processors have appropriate levels of security and organisational controls to meet data protection requirements. The information you provide will be held securely by us and/or our data processors whether the information is in electronic or physical format.

We will use the contact details you provide to us to contact you to progress your application. We will use the other information you provide to assess your suitability for the role you have applied for.

What information do we ask for, and why?

We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary.

The information we ask for is used to assess your suitability for employment. You don’t have to provide what we ask for, but it might affect your application if you don’t.

Application stage

Applications may be received by email, physically by post or through a third-party recruitment agency. We may ask you for your personal details including name and contact details. We will also ask you about your previous experience, education, referees and for answers to questions relevant to the role you have applied for. Our recruitment team will have access to this information.

You may also be asked to provide equal opportunities information. This is not mandatory information – if you don’t provide it, it will not affect your application. This information will not be made available to any staff outside of our recruitment team, including hiring managers, in a way which can identify you. Any information you do provide, will be used only to produce and monitor equal opportunities statistics.

Shortlisting

Our hiring managers shortlist applications for interview. They will not be provided with your name or contact details or with your equal opportunities information if you have provided it.

Assessments

We might ask you to participate in assessment days; complete tests or occupational personality profile questionnaires; and/or to attend an interview – or a combination of these. Information will be generated by you and by us. For example, you might complete a written test, or we might take interview notes. This information is held by the SDS Energy.

If you are unsuccessful following assessment for the position you have applied for, we may retain your details in our talent pool for a period of up to two years.

Conditional offer

If we make a conditional offer of employment we will ask you for information so that we can carry out pre-employment checks. You must successfully complete pre-employment checks to progress to a final offer. We are required to confirm the identity of our staff, their right to work in the United Kingdom and seek assurance as to their trustworthiness, integrity and reliability.

You will therefore be required to provide:

  • Proof of your identity – you will be asked to attend our office with original documents, we will take copies.
  • Proof of your qualifications – you will be asked to attend our office with original documents, we will take copies.
  • You will be asked to complete a criminal records declaration to declare any unspent convictions.
  • We will contact you to complete an application for a Basic Criminal Record check via the Disclosure and Barring Service, which will verify your declaration of unspent convictions.
  • We will contact your referees, using the details you provide in your application, directly to obtain references
  • We will also ask you to complete a questionnaire about your health. This is to establish your fitness to work. This is done through a data processor (please see below).

If we make a final offer, we will also ask you for the following:

  • Bank details – to process salary payments
  • Emergency contact details – so we know who to contact in case you have an emergency at work

Use of data processors

Data processors are third parties who provide elements of our recruitment service for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation unless they have our explicit permission or where there is a legal obligation to do so. They will hold it securely and retain it for the period we instruct.

If you are employed by SDS, relevant details about you will be provided to a number of third-party providers, including our payroll and pensions providers. All employees will be given an appropriate privacy notice to explain this in detail.

How long is the information retained for?

If you are successful, the information you provide during the application process will be retained by us as part of your employee file for the duration of your employment plus 7 years following the end of your employment. This includes your criminal records declaration, fitness to work, records of any security checks and references.

If you are unsuccessful at any stage of the process, your CV shall be retained for up to 24 months and any other information you have provided until that point will be retained for 6 months from the closure of the campaign. If you would prefer us to delete your CV, please let us know by contacting either the HR team or by contacting our Data Protection Officer on the details at the bottom of this notice.

Information generated throughout the assessment process, for example interview notes, is retained by us for 6 months following the closure of the campaign.

Equal opportunities information is retained for 6 months following the closure of the campaign whether you are successful or not.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Your rights

Under data protection legislation, you have rights as an individual which you can exercise in relation to the information we hold about you.

You can read more about these rights here – https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/

Automated decision-making

In some instances, our use of your personal information may result in automated decisions being taken (including profiling) that legally affect you or similarly significantly affect you.

Automated decisions mean that a decision concerning you is made automatically on the basis of a computer determination (using software algorithms), without human review. For example, we use automated decisions to assess the current engagement level of customers and potential customers visiting the website or otherwise engaging with SDS. We have implemented measures to safeguard the rights and interests of individuals whose personal information is subject to automated decision-making.

When we make an automated decision about you, you have the right to contest the decision, to express your point of view, and to require a human review of the decision. You can exercise this right by contact us using the contact details provided under the “How to contact us” heading below.

Complaints or queries

SDS tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.

This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of SDS’s collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below.

If you want to make a complaint about the way we have processed your personal information, you can contact the Information Commissioner’s Office in their capacity as the statutory body which oversees data protection law – www.ico.org.uk/concerns.

10   Access to personal information

SDS tries to be as open as it can be in terms of giving people access to their personal information. Individuals can find out if we hold any personal information by making a ‘subject access request’. If we do hold information about you we will:

  • give you a description of it;
  • tell you why we are holding it;
  • tell you who it could be disclosed to; and
  • let you have a copy of the information in an intelligible form.

To make a request to the SDS for any personal information we may hold you need to put the request in writing to the address provided below.

If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.

If we do hold information about you, you can ask us to correct any mistakes by, once again, contacting the SDS Data Protection Officer.

Disclosure of personal information

In many circumstances we will not disclose personal data without consent, unless legally obliged to do or as part of contractual obligations with our customers (where you are a party to the agreement or service).

We may disclose your personal information to the following categories of recipients:

  • to our company and related companies, third party services providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website), or who otherwise process personal information for purposes that are described in this Privacy Policy or notified to you when we collect your personal information.

SDS Energy’s related companies consists of:

  • SDS Energy Ltd
  • SDS Connect NI Ltd
  • SDS Connect Ltd
  • SDS Energy Group Ireland Ltd

 

  • to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
  • to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Policy;
  • to enforce or apply our Terms of Service or other agreements or to protect SDS and its customers (including with other companies and organisations for the purposes of fraud protection and credit risk reduction)
  • to any other person with your consent to the disclosure.

Legal basis for processing personal information

If you are a visitor from the European Economic Area, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with/involving you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below.

Links to other websites

This privacy notice does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.

11   Changes to this privacy notice

We keep our privacy notice under regular review. This privacy notice was last updated on 2nd May 2018

How to contact us

If you want to request information about our privacy policy, you can email us via info@sdsneergy.com or write to:

SDS Data Protection Officer

14 Pilots View

Heron Road

Belfast

BT3 9LE