Privacy Notice

1. Who we are

UTILITY PRICE CHECK LTD (“Utility Price Check”, “we”, “us” or “our”) is a company registered in Scotland.

Company name: UTILITY PRICE CHECK LTD Company number: SC898389 Registered office: Office 598, Unit LGE, 18 Young Street, Edinburgh, United Kingdom, EH2 4JB Website: utilitypricecheck.com ICO registration number: ZC223947 ADR reference: E3608 Telephone: 0333 054 0678 Privacy and compliance email: sales@utilitypricecheck.com

For the purposes of UK data protection law, UTILITY PRICE CHECK LTD will normally act as the data controller in respect of personal information that we decide how and why to process.

We provide business utility comparison, procurement, switching and intermediary services. Depending on the service requested, this may include business electricity, gas, water, telecommunications, broadband, mobile services, business waste and other services made available to business customers.

This Privacy Notice explains what personal information we collect, why we use it, where we obtain it, who we may share it with, how long we normally keep it and the rights available to individuals.

This Privacy Notice should be read together with any Cookie Policy, Terms of Business, Letter of Authority, Complaint Handling Procedure or other privacy information that we provide when collecting particular information.

2. Data protection laws

We process personal information in accordance with applicable UK data protection and privacy legislation, including, where applicable:

• the UK General Data Protection Regulation (“UK GDPR”)
• the Data Protection Act 2018
• the Privacy and Electronic Communications (EC Directive) Regulations 2003 (“PECR”)
• the Data (Use and Access) Act 2025 and amendments made by it

We seek to process personal information lawfully, fairly and transparently, to collect only information that is reasonably required for our purposes, to keep information accurate, to retain it for no longer than necessary and to protect it using appropriate technical and organisational measures.

3. What is personal information?

Personal information is information relating to an identified or identifiable individual.

In a business context this may include information about a director, sole trader, partner, employee, authorised representative, business owner or other contact person.

Information relating solely to a company or other legal entity may not itself constitute personal information. However, information such as:

• a person’s name
• a named business email address
• a direct telephone or mobile number
• a home address used as a business address
• information relating to a sole trader

may constitute personal information and will be handled accordingly.

4. Information we may collect

The information we collect depends on the service that you ask us to provide.

4.1 Identity and contact information

We may collect:

• title
• first name and surname
• job title
• position within the business
• company or trading name
• business address
• correspondence address
• email address
• telephone number
• mobile number
• preferred method of communication

4.2 Business information

We may collect:

• company name
• company registration number
• trading name
• registered address
• business address
• business type
• number and location of business premises
• nature of business
• relevant business contact information
• information required by a supplier or service provider to assess eligibility for a service

4.3 Electricity and gas information

Where you ask us to obtain or manage energy quotations, we may collect information including:

• MPAN
• MPRN
• meter serial number
• meter type
• profile class
• supply address
• current supplier
• annual consumption
• estimated annual consumption
• half-hourly or other consumption information where available and lawfully obtained
• contract start date
• contract end date
• current tariff
• current unit rates
• standing charges
• invoices and bills
• renewal information
• other technical information necessary to identify or quote for the relevant supply point

4.4 Business water information

This may include:

• SPID or other supply point identifiers
• premises address
• current retailer
• water consumption
• meter information
• invoices
• current charges
• contract details
• renewal dates

4.5 Telecommunications, broadband and mobile information

This may include:

• existing provider
• service address
• telephone numbers
• broadband or connectivity requirements
• existing services
• number of connections or SIM cards
• usage requirements
• contract details
• contract expiry dates
• information required to obtain or implement an alternative service

4.6 Business waste information

This may include:

• premises information
• current waste contractor
• waste type
• bin or container type
• quantity
• collection frequency
• current charges
• current contract details
• contract expiry date

4.7 Financial information

Where reasonably required in connection with a quotation, credit assessment or proposed contract, we may collect information such as:

• payment method
• account holder name
• business bank account number
• sort code
• Direct Debit information
• information required by a supplier or credit reference provider

We do not collect financial information simply because you have requested an initial quotation where it is not required.

Where bank information is required for the supplier application or contracting process, providing those details to us does not by itself authorise UTILITY PRICE CHECK LTD to establish a Direct Debit or conclude a supply contract on your behalf. A Direct Debit or other payment instruction will only be progressed as part of an authorised supplier contracting process.

4.8 Documents

We may receive or retain copies of documents including:

• utility bills
• supplier invoices
• contracts
• renewal notices
• Letters of Authority (“LOAs”)
• quotations
• order confirmations
• correspondence with suppliers
• complaint documents
• proof of business occupancy where required
• tenancy or change-of-occupier documentation
• other information reasonably necessary for the service requested

4.9 Website and technical information

When you use our website, we may collect certain technical information such as:

• IP address
• browser type
• device information
• operating system
• referring website
• pages visited
• approximate location derived from technical information
• date and time of access
• website interactions
• cookie or similar technology identifiers

Non-essential cookies and comparable technologies will be handled in accordance with applicable cookie and electronic communications requirements and our Cookie Policy.

5. Information we do not normally require

We do not normally need to collect special category personal information such as information concerning:

• health
• racial or ethnic origin
• political opinions
• religious or philosophical beliefs
• trade union membership
• genetic or biometric data used for identification
• sexual life or sexual orientation

Please avoid providing this type of information unless it is genuinely necessary.

If we unexpectedly receive special category information and need to retain or use it, we will ensure that an appropriate lawful basis and an additional condition required by data protection law apply.

We also do not normally require information about criminal convictions or offences.

6. How we obtain information

We may obtain information in several ways.

6.1 Information provided directly by you

You may provide information when you:

• request a quotation
• complete a website form
• telephone us
• email us
• communicate with us through social media or messaging services
• sign a Letter of Authority
• provide a utility bill
• request a supplier comparison
• request a switch or new contract
• become a customer
• make a complaint
• otherwise communicate with us

6.2 Information provided by another person within your organisation

For example, a director, manager, colleague, employee or authorised representative may provide details concerning another business contact who is involved in management of the relevant utility account.

6.3 Publicly available information

Where permitted by law, we may obtain business contact information from publicly available sources including:

• Companies House
• company websites
• public business directories
• professional directories
• publicly available social or professional networking information
• other legitimate public sources

6.4 Suppliers and service providers

We may receive information from existing or prospective:

• electricity suppliers
• gas suppliers
• water retailers
• telecommunications providers
• mobile network/service providers
• broadband providers
• business waste providers
• metering or industry data providers
• other utility service providers

This may occur, for example, when managing an existing application, confirming information about a supply point, resolving a query or handling a renewal.

6.5 Introducers and business partners

We may receive business contact information from authorised introducers, partners, sub-brokers or other organisations.

Where personal information has not been obtained directly from the person concerned, we will provide appropriate privacy information in accordance with our legal obligations, unless an applicable exemption applies.

7. Why we use personal information and our lawful bases

We will only process personal information where we have an appropriate lawful basis.

Different lawful bases may apply to different processing activities.

7.1 Responding to enquiries and preparing quotations

We use relevant contact, business and utility information to:

• understand your requirements
• identify the relevant supply or service
• obtain quotations
• compare supplier offers
• communicate quotation information
• answer your questions
• provide our intermediary services

Where the customer is an individual, sole trader or other person entering into a contract personally, this processing may be necessary to take steps at their request before entering into a contract or to perform a contract.

Where we deal with a director, employee or representative of a limited company or other corporate customer, we will generally rely on our legitimate interests in providing the requested business service, communicating with the organisation and administering the commercial relationship.

7.2 Acting under a Letter of Authority

Where you provide us with a valid Letter of Authority, we may use the information covered by that authority to contact relevant suppliers, retailers, service providers or industry data providers and to obtain information reasonably required to provide the authorised service.

Our lawful basis will depend on the circumstances and may include:

• performance of a contract or steps requested before entering into a contract; and/or
• our legitimate interests and those of the business customer in providing the authorised intermediary service

A Letter of Authority defines the authority given to us. We will not intentionally use it to exercise powers outside its scope.

7.3 Obtaining and comparing supplier quotations

We may provide relevant business and supply information to suppliers or service providers so that they can calculate or confirm quotations.

Our legitimate interest is to operate an effective business utility procurement and comparison service and provide customers with relevant commercial options.

Where processing is necessary for a contract with an individual customer, contractual necessity may also apply.

7.4 Arranging a new supply or service contract

If you decide to proceed with an offer, we may process and disclose information necessary to:

• submit an application
• confirm the supply point
• conduct eligibility checks
• facilitate credit assessment
• provide contracting information
• arrange payment information
• communicate acceptance
• assist with implementation
• support the customer during the contracting process

Depending on the customer and circumstances, our lawful basis will normally be contractual necessity and/or legitimate interests.

7.5 Credit and eligibility checks

A utility or service provider may require information in order to assess whether it is prepared to enter into a contract and on what terms.

We may therefore provide relevant information to the proposed supplier, provider or authorised credit reference service where necessary for the proposed transaction.

Where possible, we will only provide information that is reasonably required for the particular assessment.

The supplier or credit reference organisation may act as a separate data controller and may have its own privacy notice.

7.6 Managing existing contracts and renewals

We may maintain relevant contract information so that we can:

• assist with contract administration
• provide customer service
• identify approaching contract expiry dates
• contact you regarding renewal
• seek alternative quotations at an appropriate time
• assist with supplier-related queries

We generally rely on our legitimate interests in managing our customer relationships and providing an effective renewal service.

Where processing is required to perform our contractual obligations to an individual customer, contractual necessity may also apply.

7.7 Customer service and complaints

We may process relevant information to:

• answer enquiries
• investigate problems
• communicate with suppliers
• investigate complaints
• preserve evidence
• respond to data protection complaints
• establish, exercise or defend legal rights

Depending on the circumstances, we may rely on:

• legitimate interests
• contractual necessity
• compliance with a legal obligation; and/or
• processing necessary in connection with legal claims

7.8 Legal and regulatory compliance

We may process information where necessary to comply with obligations relating to matters such as:

• data protection
• accounting
• taxation
• fraud prevention
• complaints
• court orders
• lawful requests from regulators or public authorities
• other applicable legal or regulatory requirements

Our lawful basis will generally be compliance with a legal obligation.

7.9 Fraud prevention and security

We may process information where reasonably necessary to:

• protect our systems
• prevent unauthorised access
• identify fraud
• investigate suspicious activity
• protect customers
• maintain audit trails
• establish or defend legal rights

We generally rely on our legitimate interests in protecting our customers, business and information systems and, where applicable, compliance with legal obligations.

8. Direct marketing

As a business-to-business intermediary, we may contact businesses about services that we reasonably believe may be relevant to them.

Our marketing activities will be conducted in accordance with UK data protection law and PECR.

Different rules apply depending on:

• whether the recipient is a limited company or another corporate subscriber
• whether the recipient is a sole trader or certain type of partnership
• whether the communication identifies an individual
• the communication method
• whether consent has previously been provided or an objection made

8.1 Corporate business contacts

Where permitted by PECR, we may send relevant B2B marketing communications to corporate business contacts.

Where a person’s business contact details constitute personal information, we will normally rely on our legitimate interests in promoting relevant business utility services, subject to considering the person’s interests, rights and reasonable expectations.

8.2 Sole traders and certain partnerships

Different PECR rules apply to sole traders and certain partnerships.

Where PECR requires consent for electronic marketing, we will obtain the necessary consent unless another permitted exemption, such as the applicable soft opt-in provisions, applies.

8.3 Marketing telephone calls

Where applicable, we will take account of the Telephone Preference Service (“TPS”), Corporate Telephone Preference Service (“CTPS”), previous objections and our internal suppression records before making marketing calls.

8.4 Your absolute right to object to direct marketing

You have the right to object at any time to the use of your personal information for direct marketing.

If you tell us that you do not wish to receive direct marketing using your personal information, we will stop using that information for direct marketing.

You can object by contacting:

sales@utilitypricecheck.com

We may retain limited information on a suppression or “do not contact” list so that we can ensure your preference continues to be respected. This is preferable to simply deleting the objection and accidentally contacting you again later.

9. Who we may share information with

We do not sell personal information as a consumer data product.

However, running a utility intermediary business requires us to share relevant information with other organisations in certain circumstances.

We may share information with the following categories of recipient.

9.1 Electricity and gas suppliers

We may provide relevant information to suppliers where necessary to:

• obtain quotations
• verify eligibility
• submit an application
• arrange a contract
• investigate a query
• manage a renewal; or
• provide a service that you have requested

A supplier will normally act as an independent controller of personal information that it receives for its own contracting and supply purposes.

9.2 Water retailers

Where you request business water services, relevant details may be provided to water retailers or service partners to obtain quotations or arrange services.

9.3 Telecommunications, broadband and mobile providers

Relevant information may be provided to providers whose services we are quoting, arranging or administering for you.

9.4 Business waste providers

Where you request waste collection or management quotations, relevant business and contact information may be provided to selected waste providers.

9.5 Industry and metering data providers

Where permitted and necessary, we may use authorised data sources or service providers to confirm information such as:

• MPAN
• MPRN
• supply address
• meter information
• consumption
• supplier identity; or
• other information required to produce or manage an accurate quotation

Where specific consent is legally required for a particular data source or type of access, we will obtain it before using that service.

9.6 Credit reference and eligibility providers

Relevant information may be disclosed where reasonably required to support a supplier’s credit or eligibility assessment.

9.7 IT, CRM, cloud and communications providers

We may use third-party providers for functions including:

• CRM systems
• secure document storage
• cloud hosting
• email
• telephony
• website hosting
• cybersecurity
• backups
• document signing
• customer communications
• business administration

Where these organisations process personal information only on our instructions, we require appropriate contractual and security arrangements.

9.8 Professional advisers

Information may be disclosed where reasonably necessary to:

• accountants
• lawyers
• compliance advisers
• auditors
• insurers; and
• other professional advisers

9.9 Regulators and dispute resolution bodies

We may disclose relevant information to:

• the Information Commissioner’s Office
• an applicable Alternative Dispute Resolution provider
• an Ombudsman or dispute resolution body where applicable
• regulators
• courts; or
• other competent authorities

where required or appropriate for resolving a complaint or complying with legal or regulatory obligations.

9.10 Law enforcement and public authorities

We may disclose information where required by law or where a lawful request has been made by a competent authority.

9.11 Business restructuring

If UTILITY PRICE CHECK LTD is sold, merged, restructured or transfers relevant business assets, information may be disclosed to professional advisers and prospective or actual purchasers subject to appropriate confidentiality and data protection safeguards.

10. Supplier and partner responsibility for your data

Where we submit information to an electricity supplier, gas supplier, water retailer, telecommunications provider, mobile service provider, waste contractor or another service provider, that organisation may become a separate controller of the personal information that it receives.

Its own privacy notice will then apply to the processing that it carries out for its own purposes.

We recommend reviewing the privacy information provided by the relevant supplier or provider before entering into a contract.

11. Letters of Authority

Where you provide a Letter of Authority, we may use it to communicate with specified organisations and obtain the information necessary to perform the authorised services.

A Letter of Authority does not give UTILITY PRICE CHECK LTD unlimited authority over your account.

We will use an LOA only for the purposes and within the scope reasonably covered by the authority provided.

We may retain a copy of an LOA for evidence, compliance, contract administration and dispute resolution purposes.

12. Data security

We take reasonable and proportionate technical and organisational measures designed to protect information against:

• unauthorised access
• accidental loss
• inappropriate disclosure
• alteration
• destruction
• misuse; and
• other unlawful processing

Measures may include, as appropriate:

• user-specific accounts
• password controls
• multi-factor authentication where supported
• role-based access
• limiting access according to job requirements
• secure cloud storage
• encryption during transmission
• device security
• anti-malware protections
• secure backups
• access logging
• staff confidentiality obligations
• periodic review of user permissions; and
• secure disposal of documents

Access to customer information within our CRM and other systems is limited to users who reasonably require that information to perform their duties.

Users must not share login details or use another person’s account.

No internet-based or electronic storage system can be guaranteed to be completely secure. We nevertheless apply reasonable measures appropriate to the nature and sensitivity of the information we process.

13. International transfers

Some technology, communications, cloud or service providers may process information outside the United Kingdom.

Where this constitutes a restricted international transfer under UK data protection law, we will ensure that an appropriate transfer mechanism applies.

Depending on the circumstances, this may include:

• UK adequacy regulations
• the UK International Data Transfer Agreement (“IDTA”)
• the UK Addendum to approved EU Standard Contractual Clauses
• another legally recognised appropriate safeguard; or
• a permitted statutory exception

Where appropriate safeguards are relied upon, we will undertake the assessment required by UK data protection law to ensure that the protection provided for the information is not materially lower following the transfer.

You may contact us for additional information about safeguards applying to relevant international transfers.

14. How long we retain information

We do not intend to keep personal information indefinitely simply because it may be useful at some point in the future.

Retention periods depend on the purpose for which information was collected and relevant contractual, regulatory, legal and business requirements.

As a general guide:

Enquiries that do not result in a contract

Information may normally be retained for up to 24 months after our last meaningful contact, unless there is a legitimate reason to retain it for longer or you have objected to a use that requires us to retain minimal suppression information.

Quotations, customer files, contracts and LOAs

Core records may normally be retained for up to six years after the relevant service, contract or business relationship has ended, where reasonably necessary for accounting, compliance, complaint handling, evidential purposes or the establishment, exercise or defence of legal rights.

Complaint records

Complaint and dispute information may normally be retained for up to six years after closure, unless a longer period is reasonably necessary because of ongoing proceedings or another legal requirement.

Financial information

Banking and payment information will only be retained for as long as reasonably necessary for the supplier application, contract, accounting, dispute or compliance purpose for which it was collected.

We aim to avoid retaining unnecessary copies of banking information.

Marketing information

Marketing information is reviewed periodically and should not be retained longer than reasonably necessary for the marketing purpose.

Suppression records

Where someone has opted out or objected to marketing, we may retain the minimum information necessary to ensure that we continue to respect that request.

Legal proceedings

Where a complaint, investigation, regulatory matter, threatened claim or legal proceeding is ongoing or reasonably anticipated, relevant information may be retained until that matter has been finally resolved and any relevant retention period has expired.

At the end of the applicable retention period, information will be deleted, securely destroyed or anonymised where appropriate.

15. Accuracy of information

We take reasonable steps to maintain accurate and current information.

Please tell us if your:

• name
• contact information
• business address
• authorised representative
• contract details; or
• other relevant information

changes.

You can request correction by contacting:

sales@utilitypricecheck.com

16. Your data protection rights

Depending on the circumstances and the lawful basis on which information is processed, you may have the following rights.

16.1 Right of access

You may ask us whether we process personal information about you and, where applicable, request access to that information and other information required by law.

This is commonly known as a Subject Access Request (“SAR”).

16.2 Right to rectification

You may ask us to correct inaccurate personal information or complete information that is incomplete.

16.3 Right to erasure

In certain circumstances you may ask us to delete personal information.

This right is not absolute.

For example, we may need to retain information where it is necessary to comply with a legal obligation or to establish, exercise or defend legal rights.

16.4 Right to restriction

In certain circumstances you may ask us to restrict the processing of your personal information.

16.5 Right to object

You may have the right to object where we rely on legitimate interests.

We will consider your objection in accordance with applicable data protection law.

If your objection relates to direct marketing, your right to object is absolute and we will stop processing your personal information for that direct marketing purpose.

16.6 Right to data portability

Where processing is based on consent or contract and is carried out by automated means, you may in some circumstances be entitled to receive information that you provided to us in a structured, commonly used and machine-readable format or ask us to transmit it to another controller where technically feasible.

16.7 Withdrawal of consent

Where processing is based on consent, you may withdraw that consent at any time.

Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.

16.8 Rights relating to automated decision-making

UTILITY PRICE CHECK LTD does not currently intend to make decisions about individuals based solely on automated processing where those decisions produce legal or similarly significant effects.

Supplier systems may automatically calculate prices, eligibility or other information according to supplier criteria. The relevant supplier may be responsible for such processing under its own privacy notice.

If our own use of significant automated decision-making changes, we will update our privacy information and provide the safeguards required by applicable law.

17. Exercising your rights

To exercise a data protection right, please contact:

Email: sales@utilitypricecheck.com Telephone: 0333 054 0678

or write to:

UTILITY PRICE CHECK LTD Office 598, Unit LGE 18 Young Street Edinburgh United Kingdom EH2 4JB

We may need to ask for reasonable information to confirm your identity before disclosing personal information.

Where someone is acting on behalf of another individual, we may also ask for evidence of their authority.

We will respond to requests within the period required by applicable data protection law.

18. Data protection complaints

If you are unhappy about how we collect, use, disclose, retain or otherwise process your personal information, you may submit a data protection complaint to us.

You can complain by emailing:

sales@utilitypricecheck.com

Please include sufficient information to allow us to understand and investigate your concern.

We will:

• provide an accessible way for you to raise a complaint
• acknowledge receipt of a data protection complaint within the period required by law and, in any event, within 30 days
• take appropriate steps to investigate the complaint without undue delay
• keep you appropriately informed about progress; and
• tell you the outcome of our investigation

Data protection complaints are different from commercial complaints concerning an energy, water, telecommunications or other utility service. Those complaints may also be handled under our separate Complaint Handling Procedure and, where applicable, through an ADR or Ombudsman process.

19. Complaints to the Information Commissioner’s Office

You also have the right to raise concerns with the Information Commissioner’s Office (“ICO”), the independent UK regulator responsible for data protection.

Information is available from:

Information Commissioner’s Office Website: ico.org.uk

We would appreciate the opportunity to investigate and resolve your concern first, but contacting us does not remove your right to approach the ICO.

20. Cookies and website technologies

Our website may use cookies and similar technologies.

Some technologies are necessary for the website to operate securely and effectively. Other technologies, including certain analytics, advertising or tracking technologies, may require consent.

Where consent is required, they will not be used until the appropriate consent has been obtained.

Further information, including how to manage cookie preferences, is provided in our Cookie Policy.

21. External websites and social media

Our website or communications may contain links to third-party websites or platforms.

Those organisations operate under their own privacy notices and may collect information independently from us.

UTILITY PRICE CHECK LTD is not responsible for the independent data processing practices of an external website or platform merely because our website contains a link to it.

We recommend reviewing the relevant third party’s privacy information before submitting personal information.

22. Changes to this Privacy Notice

We regularly review our privacy practices and may amend this Privacy Notice when:

• our services change
• we begin using new systems or providers
• our data processing activities change
• legal or regulatory requirements change; or
• clarification is required

The latest version will be published on our website and the revision date will be shown at the beginning of the document.

Where a change materially affects how we use existing personal information, we will take reasonable steps to bring the change to the attention of affected individuals where required.

23. Contact us

Questions about this Privacy Notice, our use of personal information or your data protection rights should be directed to:

UTILITY PRICE CHECK LTD

Company number: SC898389 ICO registration number: ZC223947 ADR reference: E3608

Office 598, Unit LGE 18 Young Street Edinburgh United Kingdom EH2 4JB

Email: sales@utilitypricecheck.com Telephone: 0333 054 0678 Website: utilitypricecheck.com