1. Switchee Thermostat Privacy Notice
This Privacy Notice describes information that is collected by, and in connection with, the Switchee Smart Thermostat (“Switchee
Your landlord housing association (your “landlord”) is and will at all times be the data controller in respect of such information.
Your landlord has contracted with Switchee Limited (“We” or “Switchee”) to provide your landlord with the Switchee Thermostat and related services in connection with your home. We act as a processor of information collected by and in connection with the Switchee Thermostat, and act on behalf of your landlord, who is the controller.
We have prepared this privacy notice, approved by your landlord, to help you understand what data is collected in connection with the Switchee Thermostat, how it is used, and what your rights are in relation to it.
Between us and your landlord, we make the following commitments:
1. We will be transparent about the information we collect and how we use it
2. We will inform you before sharing your personal information with any third parties
3. We will use the best data security tools to keep your data safe and protect the Switchee Thermostat, any connected third party hardware and the Switchee data storage systems (together the “Switchee Products”) from unauthorised access.
The information that we collect and process about you will be done so in accordance with this Privacy Notice.
2. What information is collected?
o Setup Information you and your landlord provide to Switchee
o Environmental data from the Switchee Thermostat’s sensors
o Temperature or setting adjustments
o Usage Information
o Device Information
(a) Setup Information:
Your address is provided to us by your landlord, so the Switchee Thermostat can be installed at your property. Where a Switchee Thermostat is installed or serviced at a property that is already occupied, Switchee may be provided with your name and contact details by your landlord. Where you are using our Switchee app, we may also collect your email address when you register to set up an account on the App.
(b) Environmental Information:
We collect environmental data from the sensors built into the Switchee Thermostat. These include current temperature, humidity, air pressure and ambient light near the thermostat. The thermostat can also sense if there is any movement in a room, which helps indicate to the Switchee Thermostat whether a property is occupied and should be heated. Your Switchee Thermostat will use this environmental and sensor data to build a better picture of a property’s thermal performance and the efficiency of your heating system. It can also be used to gain a better understanding of your boiler’s effectiveness.
(c) Direct Adjustments to the Device:
If you change settings like temperature on the Switchee Smart Thermostat, Switchee remembers this to help understand when the heating system (boiler) is being turned on and off, and to help assist residents to use their Switchee more effectively. Recording the manual adjustments made to the device also allows Switchee to help residents with troubleshooting during customer support incidents.
(d) Usage Information
Switchee records every time your heating system turns on and off to track usage history.
(e) Device Information:
To identify and help troubleshoot any problem associated with the Switchee Smart Thermostat we record the device model, serial number, software version, and settings. Switchee does not collect IP addresses or any Wi-Fi data at the property.
3. Sharing this information with your landlord
Analysis performed by Switchee of the environmental data is shared with your landlords to show them how your property is performing, so they can understand its energy consumption, detect certain repair or maintenance issues and to help them be more proactive in maintaining the quality and comfort of your home.
We can provide insights to your landlord on:
o the likelihood of condensation, damp and mould development;
o how well the insulation and heating system are performing;
o risk of overheating in the summer and;
o risk of underheating in the winter.
This information may also be used by landlords to protect high dependency residents where Switchee detects environmental data beyond safe parameters. For example, Switchee may send notifications to the landlord if the temperature drops beyond a pre-agreed level during the winter months. In addition, your landlord will be able to schedule maintenance and energy saving advice visits when you are most likely to be available – this will help you avoid unwanted and missed visits.
This data processing and sharing is part of the service we provide to your landlord and is at all times carried out under their instruction.
4. What information is shared among multiple connected devices?
If there are any third-party devices linked to your Switchee Smart Thermostat (i.e. sensors), these products will locally share certain information with each other, such as temperature data. Sharing can also occur between the Switchee Thermostat and a mobile application, which we may develop for you, or among Switchee’s servers. A list of all third-party devices and versions that we currently use and which may be paired to a Switchee Smart Thermostat is available upon request.
5. How may Switchee and your landlord use your information?
Switchee only ever collects and processes your personal information on behalf of your landlord, who is your data controller.
Under current data protection law, your personal information can only be collected and used for certain purposes, which we describe in this
Collected usage and environmental data from the thermostat is used in order to:
o provide, develop and improve our products and services to ensure that your landlord is receiving the best service;
o deliver energy cost savings and efficiencies to you on behalf of your landlord;
o carry out analysis, and provide environmental data reports to your landlord to help them maintain your property;
o reply to any questions or enquiries about Switchee and our service to ensure the effective provision of our service to your landlord;
o contact you for your feedback on ways we can improve the delivery of Switchee services (although you can tell us at any time that you do not want to be contacted).
In addition, we may use this information in a non-identifiable form for research purposes and to help us make sales and business decisions. For example, we may use aggregated user information about the number of active thermostat users to gauge Switchee’s energy savings. This information is not personal data and as such is not subject to data protection laws.
When you register to set up an account on our Switchee app, you will need to use your email address and set up a password. We will not have access to your account name, unique ID or password, as this will be stored by our third-party provider, AWS. As such, we will only be able to see that there is an account associated with a particular Switchee device at a particular address.
6. Sharing of information between Switchee and third parties
We may share and publish non-personal information (aggregated and anonymised data) to third parties including public sector bodies, your landlords’ insurance company and research bodies.
The only anonymised information we might share in this way is: environmental information (see 2b above), data relating to adjustments (2c above) and usage data (2d above) information.
We might share such limited, non-personal information for a number of reasons which include: to illustrate things like building performance trends generally; to help us develop our services or so that others can understand what we do. For example, we may publish statistics and trends about energy use, savings and analysis of certain buildings’ energy performance. In some circumstances this may be used to influence government policies, for example those aimed at improving your home’s energy efficiency. This information is not personal data and as such is not subject to data protection laws.
We may also have to share personal data in respect of your property and Switchee device with any facilities managers appointed by your landlord to manage your property on their behalf. Such sharing of information is carried out under the instruction of your landlord.
We may share personal data in respect of you and your property to third party agents, consultants, and arms-length management organisations that your landlord / housing association have engaged, and asked us to work with. Such sharing of information is carried out under the instruction of your landlord. These third parties may have been engaged in order to assist residents such as you to achieve energy savings, and advise you on matters such as switching tariffs and introducing heat reduction measures to your property. Whilst your landlord / housing association will provide the third party with your contact details, we may be instructed by your landlord to provide them with access to your Switchee Thermostat dashboard so that they can view and assess the environmental data held there, as well as utilising the appointment scheduling and messaging facilities in order to contact you.
Where we work with employees, partners, housing providers, facilities managers or agents who are involved in delivering the Switchee services including installation of the thermostat, these arrangements will be conducted under appropriate contractual and confidentiality protections and may involve us sharing your name and address under instruction from your landlord so that these services can be delivered to you. A list of those organisations is available upon request.
If we or your landlord are reorganised or sold to another organisation, your personal information may be among the items transferred. We may also share information where we are required or allowed to do so by law.
7. Lawful Basis
Under applicable law, data controllers need to have a lawful basis to collect, use and share any of your personal information. In this case, the lawful basis relied on by your landlord in relation to the collection, analysis and sharing of any data collected from your Switchee Thermostat will depend on our and your relationship with your landlord.
For certain residents, your consent will be requested before we collect and process your personal information on your landlord’s behalf, and this will be your landlord’s lawful basis in instructing us to collect, process and analyse your personal information. This will be apparent when your consent is requested, and you will be provided with this privacy notice at the same time before we first collect your personal information.
For other residents, the lawful basis your landlord will be relying on in order to instruct us to process your personal data is its legitimate interests. This means the interests of your landlord in providing the Switchee Thermostat and connected services to you (to assist in monitoring, analysing and managing energy consumption at your property), in improving those services, and dealing with any queries that you may have. In doing this any potential negative impact on you and your rights will always be considered.
If the lawful basis your landlord is relying on is its legitimate interests, this will be made apparent to you when you are provided with this privacy notice before we start collecting and processing your personal information on your landlord’s behalf.
We and your landlord place great importance on the security of all information processed on your Switchee Thermostat and transmitted to Switchee / your landlord, and we use reasonable efforts to ensure that any information we collect directly from your Switchee Thermostat does not include personal details that can directly identify residents to Switchee.
However, third parties (including your housing provider or any other contracted service provider) may provide such details to us under instruction from your landlord. We have implemented measures to seek to protect information against loss, misuse and alteration, including encrypting all information in transmission between the Switchee Thermostat and the Switchee Server.
9. Information storage
Switchee only stores collected information linked to a property address and a landlord under instruction from your landlord. Information that is collected by Switchee via the thermostat is stored on secure servers located in the European Economic Area (“EEA”). This information may be transferred to countries outside the EEA where, for example, one or more of our servers are, in the future, located in a country outside the EEA or one of our service providers is located in a country outside the EEA. If we transfer your information outside the EEA in this way, we and your landlord will take steps to ensure that your privacy rights continue to be protected. We will retain your personal data for as long as we are instructed to do so by your landlord, which is ordinarily for two years after receipt or, if longer, until such time as it is no longer required for the purposes for which we collected your data.
10. Your Rights
UNDER DATA PROTECTION LAWS YOU HAVE VARIOUS RIGHTS THAT YOU CAN EXERCISE AGAINST THE DATA CONTROLLER IN RESPECT OF YOUR PERSONAL INFORMATION. ALL REQUESTS TO EXERCISE SUCH RIGHTS SHOULD BE DIRECTED TO YOUR LANDLORD, AS THEY ARE YOUR DATA CONTROLLER FOR THE PURPOSES OF THIS PRIVACY NOTICE. WE ARE NOT YOUR DATA CONTROLLER, BUT ARE A PROCESSOR ACTING ON BEHALF OF YOUR LANDLORD. ANY SUCH REQUESTS WE RECEIVE WILL BE REDIRECTED TO YOUR LANDLORD AND WE WILL WORK WITH THEM IN ORDER TO RESPOND TO YOUR REQUEST.
You have a legal right to ask your landlord to provide you with a copy of any personal information which is held about you in respect of the Switchee Thermostat and connected services. If you send such a request, which must be in writing, we will work with your landlord in order to provide an electronic copy of this information to you. If any of the information you receive is incorrect you can also ask us to correct these errors.
You can also ask for any of the personal information we hold about you at any time to be deleted. We will work with your landlord in order to effect this request. Please note, however, that we may not always be able to do this if there are any particular legal reasons. If this is the case, we will let you know.
If, at any time, you would like us and/or your landlord to stop collecting, storing or sharing your data, you can let your landlord know that you object to us doing this. Please note however that, we may no longer be able to provide the services to you and/or your landlord if we do this.
11. Contacting us
If you have any questions, concerns or comments about this Privacy Notice or any requests concerning your personal data, you should contact your landlord in the first instance. In any event you can contact our Data Privacy Manager via:
Email: [email protected]
Freephone: 0800 133 7957
Write to us: Makeversity, Somerset House, Strand, West Goods Entrance, London WC2R 1LA
We will work with your landlord to provide an appropriate response. If you are not satisfied with our response or believe your personal data is not being processed in accordance with the law you can complain to the UK data protection regulator, the Information Commissioner’s Office.
Further details can be found at www.ico.org.uk
or 0303 123 1113
This is version 5.0 of our Privacy Notice, updated on 14th September 2020. Please note that this Privacy Notice may change. We will provide notice
of any significant changes.
Any subsequent acknowledgment I may give in relation to this policy shall be taken as confirmation that I have read and understood the terms set out here.