THIS PRIVACY POLICY

This is the privacy notice of New Boiler Grant which is a trading style of GMS Leads Limited. New Boiler Grant (“NBG”, “we”, “us”, “our”) does not collect personal information in this website unless voluntarily submitted, or agreed to, by you.

We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). We’ll also tell you about your privacy rights and how the data protection law, including GDPR, protects you.

The purpose of this privacy notice

This privacy notice aims to give you information on how we collect and process your personal data through your use of the NBG website, including any data you may provide through this website when you apply for a new replacement boiler via this website.

This website is not intended for children and we do not knowingly or wish to collect data related to children.

You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Specifically, within NBG you will be asked to provide your personal data in respect of an application you may complete to apply for a new replacement boiler.

Data controller

GMS Leads Limited is a company registered in England and Wales under registration number 14505999. Our registered office is at 71 - 75 Shelton Street, London WC2H 9JQ.

For the purposes of data protection laws, we are the controller and responsible for your personal data. We are registered with the Information Commissioner’s Office (ICO) and our ICO registration number is ZB522342.

CONTACTING US

If you have questions about this privacy notice or our privacy practices, please contact us on ask@newboilergrant.co.uk or call 03333 601 136.

THE PERSONAL DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the ICO’s website.

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, last name, title and date of birth.

Contact Data includes postal address, email address and telephone number(s).

Property, Financial & Benefits Data, being the information you submit as part of your application including residential address, what you are looking for, whether you are a homeowner, landlord or tenant, details about your property, number of bedrooms, what type of heating you use, the type of boiler or boiling system you have, what benefits you receive or are entitled to, proof of benefits and other information evidencing your eligibility for the new boiler scheme. If you apply to NBG to purchase a new boiler on finance, then we may ask you about your financial credibility but will not undertake a credit check.

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, geographical location, operating system and platform, page interaction information and other technology on the devices you use to access this website.

Usage Data includes information about how you use our website and services.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes 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 your 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 to provide a replacement boiler. In this case, we may have to cancel your application with us but we will notify you of this at the time.

How we collect your personal data

We use different methods to collect data from and about you. You may give us your Identity, Contact and Property, Financial & Benefits Data by filling in forms or by corresponding to us by post, phone, email or otherwise. This includes personal data you provide when you:

• Apply for a new boiler;
• Request marketing information to be sent to you or for us to contact you.

In order to monitor compliance, and for quality assurance and training purposes, and in order to investigate and resolve any complaints, we also record our telephone calls with you.

Personal data about other individuals

If you provide personal data to us about another individual, you are responsible for ensuring that you have their consent to provide that data for the uses set out in this privacy notice and for bringing this privacy notice to their attention.

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:

• Performance of Contract this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.


• Legitimate Interest this means the interest of NBG in conducting and managing our business to enable us to give you the best service/product and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have an alternative lawful basis or are otherwise required or permitted to by law).


• Comply with a legal or regulatory obligation this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Except for when we seek to share your information with an approved installer (further information on this is provided below),

we do not rely on consent as a legal basis for processing your personal data. However, we rely on your consent for the following:

• sharing your information with an accredited installation company within the NBG network
• sending direct marketing communications to you via email or text message;
• non-essential cookies and in particular for marketing cookies to display personalized advertisements – for information about the cookies we use, please see our Cookie Policy.

You have the right to withdraw consent at any time by contacting us using the contact details mentioned above.

PURPOSES OF USE OF YOUR PERSONAL DATA

We have set out below, in a table format, a description of how we plan to use your personal data, with 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 in the table below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical, Property, Financial & Benefits and Usage 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 and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or made an application to NBG and have not opted out of receiving that marketing.

Your personal information may be collected, shared and used for personalized advertising. Please see further below "Who we share your personal data with".

You can ask us and/or third parties to stop sending you marketing messages at any time by contacting us using the contact details provided further above.

Cookies

Cookies may be used for personalized and non-personalized advertising. For information about the cookies we use, please see our Cookie Policy

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.

WHO WE SHARE YOUR PERSONAL DATA WITH

We may have to share your personal data with:

• An installer within our accredited installer network (however we shall not do so without your prior consent).
• Third parties who act on our behalf on a contractual basis and provide you or us with relevant services such as the conducting of surveys on our behalf.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We may also share your personal data including call recordings with regulators (including the Information Commissioner’s Office) or as required by law or regulation or the order or any court or tribunal.

We use marketing cookies to display personalized advertisements on other sites you may visit. We collect and share your personal data with selected third parties for this purpose. For more information, please see our Cookie Policy.

THIRD-PARTY LINKS OUTSIDE OF OUR CONTROL

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

When you leave our website, and visit another website, we encourage you to read the privacy notice of every website you visit.

INTERNATIONAL TRANSFERS

We generally do not seek to transfer your personal data outside the UK, though it may be necessary from time to time for us to do so, particularly when transferring to our service providers (e.g. cloud-based services) in other countries. Where that is the case, we adopt appropriate safeguards to require that your personal data will remain protected in accordance with this privacy notice and your rights are upheld. These may include implementing the relevant standard contractual clauses prescribed by the appropriate regulatory body, anonymisation, or seeking to limit a transfer to a country deemed as providing an adequate level of protection of personal data.

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 need to interact with it. 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.

DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for such as satisfying any legal, accounting, or reporting requirements.

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 requirements.

We retain your Identity, Contact and Property, Financial & Benefits Data, for the maximum period of 7 years from the end of the ECO scheme to which you are entitled.

Call recordings are kept securely and are confidentially deleted after 13 months.

YOUR LEGAL RIGHTS

To the extent permitted by, and unless subject to an exemption under, applicable data protection laws, you have the following rights with respect to your personal data:

• Your right of access - the right to request a copy of the personal data which we hold about you. This right always applies. However, there are some exemptions, which means you may not always receive all the information we process.
• Your right to rectification - the right to request that we correct any personal data if it is found to be inaccurate or out of date;
• Your right to erasure - the right in certain circumstances to request that your personal data is erased where it is no longer necessary to retain such data;
• Your right to withdraw your consent – you have the right to withdraw your consent to processing at any time, where consent was the lawful basis for processing your data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent (for example, when we have already shared your information with an approved installer with your consent);
• Your right to data portability - the right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, where applicable (i.e. where our processing is based on consent or is necessary for the performance of your contract or where we process your data by automated means);
• Your right to restriction of processing - the right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• Your right to object to processing - the right to object to our processing of personal data, where the processing is based on our legitimate interests or is for direct marketing purposes.

Exercising your rights

If you wish to exercise any of the rights set out above, please contact us using the contact details provided above in the ‘Contacting us’ section of this privacy notice.

No fee required – with some exceptions

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 manifestly unfounded or excessive. Alternatively, we may refuse to comply with your request altogether in such 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 if necessary to ask you for further information in relation to your request to speed up our response.

If you have made a new boiler application, then we may ask you to confirm the Memorable Word that you will have provided so as to validate your identity.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may 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.

CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

We reserve the right to change this Policy at any time without notice. Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.

QUERIES, REQUESTS OR CONCERNS

To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact us on ask@newboilergrant.co.uk or 03333 601 136.

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the ICO, which can be contacted at: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF www.ico.org.uk The ICO helpline number is 0303 123 1113.