Privacy Policy

Electron’s privacy policy | Version 1.3

This privacy policy was last updated on August 22, 2024

Introduction
Who is the controller or processer of your data?
What type of personal information do we collect?
How do we obtain your data?
What is our lawful basis for processing your data?
How do we process your data?
Who do we share your data with?
Where do we store your data?
How long do we hold your data for?
How do we keep your data secure?
What are your rights?
How we respond to “do not track” signals
Links to other websites
Changes to the terms of this privacy policy
Making a complaint

1. Introduction

We respect your right to privacy and have put in place security measures for your personal data, along with ensuring that your personal data is managed in accordance with applicable data privacy regulations.

This privacy policy explains what personal data we hold about you, how we collect it, who we share it with, how it is secured, and what your rights are in relation to your personal data.

2. Who is the controller or processor of your data?

The controller or, where applicable, processor of your data is Chaddenwych Services Ltd t/a Electron. The principles set out in this privacy notice apply to all instances in which Chaddenwych Services Ltd t/a Electron receives your personal data as a data controller for the purposes described in this notice.

You can find our contact details below.

Our company name: Chaddenwych Services Ltd t/a Electron
Our company number: UK Companies House: 09914060
Our Country of registration: England
Our registered office: 86-90 Paul Street, London, England, EC2A 4NE
Our website: https://electron.net/

3. What type of personal information do we collect?

We collect personal data that you voluntarily provide to us when you express an interest in getting information about us or our products, services and content, or when you contact us. Where personal data is collected on the website, we will give details on why your personal information is needed and how it will be used, unless it’s obvious.

We also automatically collect certain information when you visit, use or navigate through our website. This information does not reveal your identity, such as your name or contact information, but may include information about your device and usage.

This section lists what data we may hold about you in connection with your dealings with Electron.

Names: Your first name, middle names and last names.
Phone number: Your telephone number supplied to us, and/or any public telephone number published by any company or organisation you represent.
Email address: This will be the email address – either business or personal – that is supplied to us.
Job title: Your job title or role at the company or other organisation you represent or work for.
Company name: The name of any company or other organisation you are representing or work for.
Relationship: Your relationship with us, such as whether you are a client, potential sales opportunity, partner or other.
Enquiries: Any queries and other enquiries that you raise with us, and responses that we give you. For example, if you submit a book a demo request through the website.
Communications: Any emails and messages, and notes of any calls, between you and us.
Log-Ins: Log-in and account details where you are given access by us to any system (e.g. SaaS system) or resource (e.g. user guides). Data concerning your logging in to and use of our systems, to track and monitor correct usage, and to support our clients in dealing with wrongful usage.
Website usage data: We capture information about visits to our website, which our cookie policy breaks down in more detail. This data may include when you visited, IP address, web browser, operating system, your location, the pages you visited and the areas of the page you visited. This information collected does not reveal your specific identity, and is stored and used in an anonymous form, unless you’re added to HubSpot. In such cases, the information may be linked to you.
Usage Information: If you are given user rights to access any of our systems, then we may record and store information about your use of those systems, including APIs called and tasks undertaken in the systems.
Video Call Recordings: If you opt to share your video feed or audio during any video call or conference organised and recorded by us, your image and voice may be captured. This includes events such as business updates, training sessions, or conferences.
Billing information
Contact preferences
Cookie preferences
Interest in our marketing campaigns and products

3.1 Registered users of ElectronConnect

Flexibility Service Providers (FSPs)

We collect your contact information (incl. your name, email and telephone number), information about the customer you are trading on behalf of, information about your user credentials and the device you are using to connect to ElectronConnect as well as activities conducted on our platforms such as registering assets or submitting offers. The information is used to:
- Provide our services to you and the customer you are trading on behalf of.
- Issue notifications and other important communications to you.
- Provide information about orders and transactions to the customer you are trading on behalf of and to regulatory authorities when required by law.
- To ensure adequate security of personal data and the confidentiality, integrity and availability of the trading platforms.

In addition, we may collect contact information (incl. your name, email and telephone number) or information about the customer you are trading on behalf of (typically your employer) via a third-party platform or organisation (e.g. another market platform, or the Distribution System Operator.

Market Operators

We collect your contact information (incl. your name and email), information about your user credentials and the device you are using to connect to ElectronConnect as well as activities conducted on our platforms such as operating markets. The information is used to:
- Provide our services to you.
- Issue notifications and other important communications to you.
- Provide information to regulatory authorities when required by law.
- To ensure adequate security of personal data and the confidentiality, integrity and availability of the trading platforms.

4. How do we obtain your data?

Most of the personal information we process is provided to us directly by you for one of the following reasons:

Forms you complete, including any demo requests and general enquiries on our websites, and any marketing content downloads such as publications and newsletters.
Documents you send to us, and emails and messages you send, and from your public LinkedIn account.
Conversations directly with you, which may include phone calls, video calls, emails, LinkedIn messaging or otherwise.
Your web browser and email domain, including data automatically provided by your web browser when you visit our website, data collected through your browser by cookies and similar technologies, and from tracking technology in our marketing emails which tells us when an email was engaged with.

We may also collect data from different sources, including third parties. This information may be combined with data we gather directly from you to enhance our understanding and service offerings. Sources may include third-party business information providers and publicly accessible platforms, such as social media. The types of information we may collect include physical mail addresses, job titles, email addresses, phone numbers, IP addresses, and social media profiles.

5. What is our lawful basis for processing your data?

To process your data, we must have a lawful reason for doing so. Under the EU Regulation 2016/679 UK General Data Protection Regulation (“GDPR”), the lawful bases we rely on for processing this information are:

Consent: This could be explicit documented consent, or it could be implicit because you have requested some action to be taken involving your data. You can remove your consent at any time by contacting marketing@electron.net.
Contractual obligation: Data processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract with them.
Legal obligation: We need to process your data to comply with a legal obligation or exercise a legal right.
Vital interests: To protect your vital interests which could include care for your health and safety or protecting your life or that of another natural person.
Public interests: Data processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller.
Legitimate interests: We process your data for our legitimate interests or those of third parties, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in where the data subject is a child.

Electron does not collect personal data classified in GDPR as “special category data” (also known as “sensitive personal data”), for example, data concerning the data subject’s race, ethnicity, politics, religion, trade union membership, genetics, biometrics (if used for ID purposes), health, sex life, or sexual orientation).

6. How do we process your data?

The following section outlines the various ways we use your data for.

Enquiry follow-up
- Following up on any requests or enquiries you made through the website such as through the demo request form or contact us form.
- Lawful basis: Legitimate interest – We are responding to an enquiry you made, and you have implicitly requested our response by submitting your form.
Marketing
- We use your information to market our products and services to you through channels such as email marketing and paid social media i.e., LinkedIn
- Lawful basis: Your consent. You are able to remove your consent at any time by contacting us on marketing@electron.net.
Relationship management
- We use this information to manage the relationships between our business and you and/or the company or organisation you work for.
- Lawful basis:
  - Contractual obligation: To effectively perform and manage a contract between you and us, or the company or organisation you work for.
  - Legitimate interest: We are unable to manage our contracts properly without being able to contact our client or other party connected to the contract.
System management
- We use this information to manage your access to and usage of the systems you are given access to. For example, to communicate with you about your access, revoke access, authenticate and authorise access.
- Lawful basis:
  - Contractual obligation: To perform a contract
  - Legitimate interest: To protect the rights interests of our clients’ in relation to their data you may have access to. To protect our rights and interests in relation to our data and information in the system. To maintain the security of our systems and be able to detect and evidence wrong-doing.
Training and information sharing
- We may use your video and voice call recordings to keep evidence of the call and incidentally in connection with sharing that video or call in our business. We will always notify you before recording any video or voice call.
- Lawful basis: Legitimate interest – to be able to share training and business updates in our business to those not able to attend and to keep a proper record for the effective performance of our business.
Website improvements
- We use data to observe and analyse user interactions throughout our website. This enables us to improve the functionality of our services and innovate new features, to help increase website traffic and enhance our search engine rankings. All data used for this purpose is processed in an anonymised format.
- Lawful basis: Legitimate Interest- To be able to promote and grow our business through an effective and relevant website.

This section outlines who we may share your information with. We will never sell your personal information.

Auditors
- Any third party auditing our business and controls, including our security measures and operational controls, for evidence purposes, but only to the extent reasonably required for such evidence. It will be shared securely, and under a non-disclosure agreement; and is shared normally to the auditors’ secure evidence repository.
Other third party providers
- We work with third party services who provide website development, hosting, maintenance, and other services for us. These third parties may have access to or process personal data as part of providing these services to us. We limit the information provided to only what is reasonably necessary to perform these functions, and require them to handle your personal information as if we were handling it directly.
Other staff
- We may share your information with other staff who are involved in engaging you.
Compliance with law
- We may disclose personal information if required to do so by law, or to otherwise cooperate with law enforcement or governmental agencies. We reserve the right to disclose personal data in order to take precautions against liability, or protect ourselves or others from fraudulent or unlawful uses or activity.

7.1 Sub processors and other third-party service providers

We work with third party services who provide website development, hosting, maintenance, and other services for us. These third parties may have access to or process personal data as part of providing these services to us. We limit the information provided to only what is reasonably necessary to perform these functions, and require them to handle your personal information as if we were handling it directly.

Sub processor	Activities undertaken
Correla	Customer Service and 1st line application support

8. Where do we store your data?

HubSpot
- HubSpot is our Customer Relationship Management (CRM) system which we use for marketing activities and their form feature so visitors can submit forms through the website.
Microsoft 365, Gmail, Slack and SharePoint
- Electron uses Microsoft 365, Gmail, Slack and SharePoint for its general email, messaging, document creation, document storage and document sharing.

Electron shall ensure that the following measures are taken with respect to the storage of personal data:

All electronic copies of personal data is stored securely using strong and secure passwords
No personal data is stored on any mobile device (including, but not limited to, laptops, tablets, and smartphones; and
No personal data is transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of Electron where the party in question is bound by adequate confidentiality agreements.

9. How long do we hold your data for?

In general, we will only hold your information for as long as it is required for the purposes set out in this privacy policy. We may also retain log files for analysis purposes – these log files are generally retained for a short period of time, except in cases where the information is used for website security, improving the website functionality, and in the cases in which we are legally obligated to retain information for longer time periods.

10. How do we keep your data secure?

We take security very seriously and are committed to keeping your information safe. Whilst we aim to ensure the security of our systems and the information we hold; no service is guaranteed to be completely secure. If you have any concerns that your personal information has been put at risk, please get in touch.

We are certified to ISO27001 standards, which requires a robust level of information security to be implemented into all aspects of our business. This ensures that all information is handled safely and securely.

10.1 Data breach

We have procedures in place to deal with any suspected data security breaches affecting your personal information. In the event of a breach, we will assess the situation and, where legally required, notify you and the relevant regulatory authorities.

11. What are your rights?

You have the following rights with respect to the processing your personal data, but please note that these rights may be subject to conditions and exceptions set out in the law.

The UK GDPR facilitates a number of rights for you to access, rectify and delete your data. Your rights are:

Right to be informed: You have the right to ask us how and why we are processing your personal data. If we have provided this to you in the form of this Privacy notice, we will inform you. Where processing has not been identified in this notice, we will provide you with details of what data we are processing, why we are processing it, where we are processing it and how it is being processed.
Right to Access: You have a right to access and have a copy of your information provided to you.
Right to Rectification: You have the right to have your data updated where inaccuracies have occurred and for that data to be completed, where it remains incomplete.
Right to erasure (Also knows as the Right to be Forgotten): You have the right to request that Electron erases your personal data in the following circumstances:
- It is no longer necessary for Electron to hold that personal data with respect to the purpose(s) for which it was originally collected or processed;
- You have withdrawn your consent for us to process that data;
- If you have objected to the use of your data and we can no longer justify the reason for processing your data,
- You have objected to direct marketing we undertake;
- The personal data has been processed unlawfully; or
- There is a legal obligation which requires us to erase the data

Unless Electron has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one month of receipt of the data subject’s request. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.

If any personal data that is to be erased in response to a data subject’s request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).

To request for the erasure of your personal data please contact support@electron.net.

Right to data portability: Where you have provided data to us and Correla is the Data Controller, you have the right to be provided your data in a format that enables you to transfer that data to another provider.
Right to object to processing: You have the right to object to our processing of your personal data based on legitimate interests, direct marketing (including profiling), and processing for scientific and/or historical research and statistical purposes.

12. How we respond to “do not track” signals

Our website does not respond to “do not track” (DNT) signals, but we offer options to opt-out of certain data collection practices, such as marketing. DNT is a privacy preference that you can set in your web browser to let websites know that you do not want to have your online activities tracked. Currently, there is no industry standard for how to interpret and respond to DNT signals, and therefore, we do not change our data collection and use practices when we receive such signals from your browser.

13. Links to other websites

This website may contain links to other websites which are outside of our control and, as such, are not covered by this privacy policy. If you access another website via a link on Electron’s website, the operators of these sites may collect your information in accordance with their own privacy policies. You will need to read the privacy policy on that website to find out if/how they collect and/or use your information.

14. Changes to the terms of this privacy policy

Please revisit this page periodically to stay aware of any changes to this privacy policy, which we may update sometimes. If we modify the notice, we will indicate the version number and date of the latest revision at the top of this page. If we believe that the changes are material, we will let you know about these by either posting the changes to our website and/or emailing you to inform you of the changes. Your continued use of our services after the privacy policy has become effective indicates that you have read, understood, and agreed to the current version of the policy.

15. Making a complaint

We hope that we can resolve any query you may have, but you also have the right to complain to the Information Commissioner’s Office (ICO) at any time.

Their details are:

Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Helpline number: 0303 123 1113