NIBE PRO INSTALLER PRIVACY NOTICE
1. IMPORTANT INFORMATION AND WHO WE ARE
The NIBE Pro Installer Programme is not intended for children and we do not knowingly collect data relating to children.
Full name of legal entity: NIBE Energy Systems Limited
Email address: firstname.lastname@example.org
Postal address: Unit 3c Broom Business Park, Bridge Way, Chesterfield, Derbyshire, S41 9QG
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, gender, maiden name, last name, title, job title, employer, professional qualifications and/or accreditations, national insurance number, driving licence, passport and date of birth.
- Contact Data includes email address, mobile numbers and telephone numbers.
- Training Data includes information about the training you receive from us, your unique learner number, your performance as part of such training and any professional qualifications and/or accreditations you earn or are awarded as a result of such training.
- Financial Data includes bank account and payment card details (where you use a personal bank account and/or payment card in order to pay us for NIBE products).
- Transaction Data includes details about payments to and from you and other details of NIBE products you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website, the NIBE Pro Web Portal and/or NIBE Pro Web Shop.
- Profile Data includes your username and password and how many points you have earned as a result of registering the warranties of NIBE products.
- Usage Data includes information about how you use our website, the NIBE Pro Web Portal, the NIBE Pro Web Shop and NIBE products, purchases or orders made by you via the NIBE Pro Web Portal and what rewards you have claimed via the NIBE Pro Web Shop.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
As part of your application to the NIBE Pro training and certification scheme, we may also collect Special Categories of Personal Data about you (this may include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity Data, Contact Data, Financial Data, Training Data, Profile Data or Marketing and Communication Data by filling in forms, taking part in training or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Apply to be a member of the NIBE Pro Installer Programme;
- Take part or apply to take part in training as part of the NIBE Pro Installer Programme
- Purchase or apply to purchase NIBE products;
- Create or register an account on our website and/or the NIBE Pro Web Portal;
- Request marketing to be sent to you; or
- Give us feedback or contact us.
- Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
- Technical Data from analytics and search information providers such as Google, some of which are based outside the UK.
- Contact Data, Financial Data and Transaction Data from providers of technical, payment and delivery services such as Stickers & That, Sage, Orderwise and Nimble, some of which may be based outside the UK.
- Identity Data and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.
Purpose/Activity, Type of data Lawful basis for processing including basis of legitimate interest
To register you as a NIBE Pro Installer:
(c) Training Performance of a contract with you
To process and deliver your orders for NIBE products including:
(a) Managing payments, fees and charges
(b) Collecting and recovering money owed to us
(c) Delivering training courses to you and assessing your practical skills (a) Identity
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To deliver training courses to you and assessing your practical skills as part of the NIBE Pro Installer Programme (a) Identity
(c) Training Necessary for our legitimate interests (to ensure members of the NIBE Pro Installer Programme have the requisite training, qualifications and accreditation)
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(c) Recording your registration of warranties of NIBE products and the points you earn as a result under the NIBE Pro Installer Programme
(d) Carrying out regular checks on your business in order to establish whether you satisfy the criteria for being part of the NIBE Pro Installer Programme, including but not limited to records of insurances and other industry certification
(e) Sending you communications regarding the availability of applicable training and/or NIBE products
(f) Generally administering the NIBE Pro Installer Programme (a) Identity
(f) Usage (a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study the performance of our installers under the NIBE Pro Installer Programme)
To enable you to redeem the points you earn under the NIBE Pro Installer Programme for rewards via the NIBE Pro Web Shop (a) Identity
(d) Usage (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study the performance of our installers under the NIBE Pro Installer Programme and reward installers for good performance)
To carry out regular checks in order to ensure that you continue to satisfy the criteria for membership of the NIBE Pro Installer Programme (a) Identity
(e) Usage (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to ensure members of the NIBE Pro Installer Programme have the requisite training, qualifications and accreditation)
To administer and protect our business and the NIBE website, NIBE Pro Web Portal and NIBE Pro Web Shop (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(c) Technical (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To use data analytics to improve the NIBE website, NIBE Pro Web Portal and NIBE Pro Web Shop, products, marketing, customer relationships and experiences (a) Technical
(c) Profile Necessary for our legitimate interests (to define types of customers for our products to keep our website, the NIBE Pro Web Portal and NIBE Pro Web Shop updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about NIBE products that may be of interest to you or your customers (a) Identity
(f) Marketing and Communications Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, training and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased NIBE products from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of the purchase of a NIBE product, warranty registration, product experience or other transactions.
When you visit the NIBE website, it will store or retrieve information on your browser, mostly in the form of cookies. This information might be about you, your preferences or your device and is mostly used to make the NIBE website work as you expect it to. The information does not usually directly identify you, but it can give you a more personalised web experience.
We use the following cookies:
- Strictly necessary cookies. These cookies are necessary for the NIBE website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms.
- You can set your browser to block or alert you about these cookies, but some parts of the NIBE website will not then work.
- Analytical or performance cookies. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of the NIBE website. They help us to know which pages are the most and least popular and see how visitors move around the NIBE website.
- All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited the NIBE website, and will not be able to monitor its performance.
- Functionality cookies. These cookies enable the NIBE website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to the pages of the NIBE website.
- If you do not allow these cookies, then some or all of these services may not function properly.
- Targeting cookies. These cookies may be set through the NIBE website by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites.
If you do not allow these cookies, you will experience less targeted advertising.
You can ask our data privacy manager for more information about the individual cookies we use and the purposes for which we use them by using the contact details set out above.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the table above.
- Other companies in the NIBE Group acting as joint controllers or processors and who are based in Sweden and provide IT and system administration services and undertake leadership reporting.
- Service providers acting as processors based in the UK, USA and Sweden who provide IT, CRM and system administration services.
- Third party training providers, quality assurance scheme providers, competent persons schemes and accreditation bodies acting as processors or joint controllers based in the UK who provide training and accreditation services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
- Debt collection agencies, credit check providers and credit reference agencies acting as processors or joint controllers based in the UK who provide debt collection and credit checking services to us from time to time.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
We share your personal data within the NIBE Group. This will involve transferring your data outside the UK.
Many of our external third parties are also based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data;
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
In some circumstances you can ask us to delete your data; see below for further information on this.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.