1. Privacy Notice for Switchee
This Privacy Notice describes information that Switchee Limited (“We” or “Switchee”) collect, use, share and store, including personal information, for which We are the data controller.
- We will be transparent about the information we collect and how we use it
- We will inform you before sharing your personal information with your landlord and with any third parties
- We will use the best data security tools to keep your data safe and protect the Switchee Smart Thermostat (“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 does Switchee collect?
- Setup Information you and your landlord provide
- Environmental data from the Switchee Thermostat’s sensors
- Temperature or setting adjustments
- Usage Information
- 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. Why is this information shared with my 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:
- the likelihood of condensation, damp and mould development;
- how well the insulation and heating system are performing;
- risk of overheating in the summer and;
- 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.
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 use your information?
Under current data protection law, we can only collect and use your personal information for certain purposes, which we describe in this section.
We use collected usage and environmental data from the thermostat in order to:
- provide, develop and improve our products and services;
- deliver energy cost savings and efficiencies to you;
- carry out analysis, and provide environmental data reports to your landlord to help them maintain your property;
- reply to any questions or enquiries about Switchee and our service;
- 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.
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 Switchee 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.
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.
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. 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 asked and agree to provide them with access to your Switchee Smart 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 so that these services can be delivered to you. A list of those organisations is available upon request.
If we’re 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, we need to have a lawful basis to collect, use and share any of your personal information. In this case, the lawful basis we rely on 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, we will request your consent before we collect and process your personal information, and this will be our lawful basis. 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 we will be relying on in order to process your personal data is our legitimate interests. This means the interests of our business in providing services to landlords and to you, in improving those services, and dealing with any queries that you may have. In doing this we will always consider and balance any potential negative impact on you and your rights.
If the lawful basis we are relying on is our 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.
We place great importance on the security of all information processed on your Switchee Thermostat and transmitted to Switchee 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. 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. 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 will take steps to ensure that your privacy rights continue to be protected. We will retain your personal data for two years after receipt or, if longer, until such time as we no longer require it for the purposes for which we collected your data.
10. Your Rights
You have a legal right to ask us to provide you with a copy of any personal information which we hold about you or is related to you. If you send us such a request, which must be in writing, we will provide an electronic copy of this information to you. If any of the information we send you is incorrect you can also ask us to correct these errors.
You can also ask us to delete or remove any of the personal information we hold about you at any time. 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 to stop collecting, storing or sharing your data, you can let us 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 can contact our Data Protection Officer via:
Email: [email protected]
Freephone: 0800 133 7957
Write to us: Base KX, 103C Camley Street, Kings Cross, London N1C 4PF
If you are not satisfied with our response or believe we are processing your personal data not 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 4.2 of our Privacy Notice, updated on 21st April 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.