Privacy Notice

1. Who We Are

UK Energy Management Group Ltd ("UKEM", "we", "us", "our") is the data controller responsible for your personal data.

We are registered with the Information Commissioner's Office (ICO) under registration number ZA889082.

Company details:

• Company name: UK Energy Management Group Ltd
• Company number: 10830291
• Registered address: 6 Crown Road, Quay West Business Village, Sunderland, SR5 2AL
• Data protection contact: customercare@ukem.co.uk | 0800 222 9494

2. What Personal Data We Collect

We may collect the following categories of personal data depending on how you interact with us:

2.1 Data You Provide Directly

• Full name, postal address, email address, and telephone number
• Date of birth (where required for finance applications or ECO4 eligibility)
• Property details (address, property type, tenure, heating system, wall type, EPC rating)
• Benefit and income information (for ECO4 eligibility checks only)
• Photographs of your property submitted via our upload tool
• Signature (electronic or handwritten, for consent forms and contracts)
• Payment information (processed securely by our payment provider; we do not store card details)
• Communications with us (emails, web forms, phone calls, text messages)
• Call recordings (you will be informed at the start of any recorded call)
• Marketing preferences and consent

2.2 Data We Collect Automatically

• IP address, browser type, device type, and operating system
• Pages visited, time spent on pages, referring URLs, and click patterns
• Cookie and tracking data (see our separate Cookies Policy for full details)

2.3 Data We Receive from Third Parties

• ECO4 eligibility confirmation from the Department for Work and Pensions (DWP) via Energy Saving Trust (benefit status only - not which benefit)
• Property ownership verification via HM Land Registry through Energy Saving Trust
• Energy Performance Certificate (EPC) data from public registers
• Credit check outcomes from Shermin Finance Limited and their panel lenders (for finance applications)

If you provide us with personal data about another person (for example, a household member for an ECO4 check), you confirm that you have their consent for it to be used as described in this notice.

Some personal data is required so that we can provide a quotation, enter into a contract, arrange installation, assess eligibility for government-backed schemes or finance, and comply with legal and regulatory requirements. If you do not provide the requested information, we may be unable to provide some or all of our services.

3. How We Use Your Personal Data

We use your personal data for the following purposes:

Purpose	Data Used	Lawful Basis
Providing a quotation for products and services	Name, address, property details, contact details	Contractual necessity (steps prior to entering a contract)
Processing your order and managing the installation	Name, address, contact details, property photos, payment details, contract documents	Contractual necessity (performance of a contract)
ECO4 eligibility assessment	Name, address, date of birth, benefit status, tenure, property details, EPC	Consent (you consent to the DWP check via the eligibility form)
Finance applications via Shermin Finance	Name, address, date of birth, income information, credit check results	Contractual necessity (processing your finance request) and consent (where required for credit checks or referral to lenders)
BUS grant, OZEV grant, MCS, and SEG applications	Name, address, property details, installation details, EPC	Contractual necessity and legal obligation
Recording telephone calls for quality and training	Voice recording, name, account details discussed	Legitimate interests: to monitor service quality, train staff, investigate complaints, and establish, exercise or defend legal claims
Sending marketing communications about products, services, and offers	Name, email address, telephone number, marketing preferences	Consent (where you opt in) or legitimate interest (where you are an existing customer and we contact you about similar products and services)
Website analytics and performance improvement	IP address, cookie data, and browsing behaviour	Consent (via cookie consent tool) and legitimate interests: to understand how visitors use our website and improve its content and functionality
Displaying advertising on third-party platforms	Cookie identifiers, browsing behaviour	Consent (via cookie consent tool)
Complaints handling and dispute resolution	Name, contact details, correspondence, call recordings	Legal obligation and legitimate interests: to investigate and resolve complaints and establish, exercise or defend legal claims
Compliance with legal and regulatory obligations (Ofgem audits, FCA, RECC, Gas Safe, MCS)	All relevant data as required by the applicable regulatory body	Legal obligation

4. Who We Share Your Data With

We may share your personal data with the following recipients where necessary. We will never sell your personal data to third parties for their own marketing purposes.

• UKEM group companies, for legitimate internal business purposes
• Shermin Finance Limited (FRN 727594) and their panel of lenders, for credit applications
• Approved subcontractors and engineers carrying out installations on our behalf
• Technology and service providers who process data on our behalf (including CRM, telephony, forms, chat, email marketing, review platforms, analytics, and advertising tools)
• Energy Saving Trust and the Department for Work and Pensions (DWP), for ECO4 and GBIS eligibility checks (with your explicit consent). DWP will only confirm whether you receive a qualifying benefit, not which one.
• HM Land Registry, via Energy Saving Trust, for property ownership verification (with your consent)
• Ofgem, for BUS grant applications, ECO4 compliance, and scheme audits
• OZEV, MCS, RECC, NAPIT, Gas Safe Register, and local authority building control, for certification, registration, and regulatory compliance
• Obligated energy suppliers, where required under ECO4 scheme rules
• Law enforcement and regulatory authorities, where required by law

Some of the organisations listed above process your personal data as independent data controllers for their own purposes, including finance providers, certification bodies, scheme administrators, regulators, and public authorities. Those organisations are responsible for providing their own privacy information where required.

You can withdraw your consent for data sharing with DWP via Energy Saving Trust by contacting us. If you withdraw consent, data already processed will be retained as required for regulatory audit purposes, but no new data will be collected or shared.

5. International Data Transfers

Some of our technology providers may process data outside the United Kingdom. Where this occurs, we ensure that appropriate safeguards are in place, such as adequacy regulations or approved contractual safeguards, where required by UK data protection law. If you would like more information, please contact us at customercare@ukem.co.uk.

6. Data Security

We have implemented appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction, or damage. Whilst we take all reasonable steps to protect your data, no method of transmission over the internet or electronic storage is 100% secure.

7. How Long We Keep Your Data

We retain your personal data for as long as necessary to fulfil the purposes for which it was collected, comply with our legal and regulatory obligations, and protect our legitimate interests. As a guide:

• Enquiries and quotations that do not proceed: up to 24 months
• Customer contract and installation records: duration of contract plus warranty period plus applicable limitation period
• Scheme and compliance records (ECO4, MCS, Gas Safe, Ofgem): as required by scheme rules and regulatory bodies
• Finance application data: as required by finance partner and legal obligations
• Call recordings: up to 24 months, or longer where needed for an active complaint or dispute
• Marketing suppression records: as long as needed to honour your opt-out request

If you ask us to delete your personal data, we will do so unless there is a legal or regulatory reason that requires us to retain it. Where we are required to keep data for regulatory purposes, we will inform you and explain why.

8. Your Rights

Under UK data protection law (UK GDPR and the Data Protection Act 2018), you have the following rights:

• Right of access - you can request a copy of the personal data we hold about you (a 'subject access request').
• Right to rectification - you can ask us to correct any inaccurate or incomplete data.
• Right to erasure - you can ask us to delete your personal data in certain circumstances (e.g. where consent is withdrawn and there is no other legal basis).
• Right to restrict processing - you can ask us to limit how we use your data in certain circumstances.
• Right to data portability - you can request your data in a structured, commonly used, and machine-readable format.
• Right to object - you can object to processing based on legitimate interests or for direct marketing purposes.
• Right to withdraw consent - where processing is based on consent, you can withdraw it at any time without affecting the lawfulness of processing before withdrawal.
• Rights related to automated decision-making - we do not make solely automated decisions about you that produce legal or similarly significant effects. If you apply for finance, the finance provider or lender may carry out automated credit checks or decision-making under their own privacy notice.

To exercise any of these rights, please contact us at customercare@ukem.co.uk. We will respond within one month of receiving your request.

9. Data Protection Complaints

If you believe we have handled your personal information in a way that breaches data protection law, you have the right to make a data protection complaint. This right is provided in accordance with Section 164A of the Data Protection Act 2018 (as inserted by the Data (Use and Access) Act 2025).

The full procedure, including how to submit a complaint, what happens next, our response timeframes, and how to escalate to the Information Commissioner's Office (ICO), is set out in Section 6 of our Complaints Procedure.

10. Marketing Communications

We may contact you about products, services, and offers that may be of interest to you. Where you are a new contact, we will only do so with your consent. Where you are an existing customer, we may send you marketing by email or text about our own similar products and services where permitted by law, provided you were given the opportunity to opt out when your details were collected and in every subsequent message.

You can opt out of marketing at any time by:

• Clicking the 'unsubscribe' link in a marketing email, where available
• Emailing customercare@ukem.co.uk and asking to be removed from our marketing list
• Writing to us at our registered address

Opting out of marketing will not affect any service-related communications we need to send you (for example, installation appointment confirmations or warranty information).

11. Children's Data

Our website and services are not directed at individuals under the age of 18. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data about a child, please contact us and we will delete it promptly.

12. Changes to This Privacy Notice

We may update this Privacy Notice from time to time. The date at the top of this page indicates when this notice was last updated.