the paper work...

Privacy policy.

TERMS OF WEBSITE USE


This terms of use (together with the documents referred to in it) tells you the terms of use on
which you may make use of our website www.inenco.com (our site), whether as a guest or a
registered user. Use of our site includes accessing, browsing, or registering to use our site.
Please read these terms of use carefully before you start to use our site, as these will apply to
your use of our site. We recommend that you print a copy of this for future reference.
By using our site, you confirm that you accept these terms of use and that you agree to
comply with them.
If you do not agree to these terms of use, you must not use our site.


OTHER APPLICABLE TERMS


These terms of use refer to the following additional terms, which also apply to your use of
our site:
 Our Privacy Policy , which sets out the terms on which we process any personal data
we collect from you, or that you provide to us. By using our site, you consent to such
processing and you warrant that all data provided by you is accurate.
 Our Cookie Policy, which sets out information about the cookies on our site.


CHANGES TO THESE TERMS


We may revise these terms of use at any time by amending this page.
Please check this page from time to time to take notice of any changes we made, as they are
binding on you.
CHANGES TO OUR SITE
We may update our site from time to time, and may change the content at any time. However,
please note that any of the content on our site may be out of date at any given time, and we
are under no obligation to update it .
We do not guarantee that our site, or any content on it, will be free from errors or omissions.

ACCESSING OUR SITE

Our site is made available free of charge.
We do not guarantee that our site, or any content on it, will always be available or be
uninterrupted. Access to our site is permitted on a temporary basis. We may suspend,
withdraw, discontinue or change all or any part of our site without notice. We will not be
liable to you if for any reason our site is unavailable at any time or for any period.
You are responsible for making all arrangements necessary for you to have access to our site.
You are also responsible for ensuring that all persons who access our site through your
internet connection are aware of these terms of use and other applicable terms and conditions,
and that they comply with them.

INTELLECTUAL PROPERTY RIGHTS


We are the owner or the licensee of all intellectual property rights in our site, and in the
material published on it. Those works are protected by copyright laws and treaties around the
world. All such rights are reserved.
You may print off one copy, and may download extracts, of any page(s) from our site for
your personal use and you may draw the attention of others within your organisation to
content posted on our site.
You must not modify the paper or digital copies of any materials you have printed off or
downloaded in any way, and you must not use any illustrations, photographs, video or audio
sequences or any graphics separately from any accompanying text.
Our status (and that of any identified contributors) as the authors of content on our site must
always be acknowledged.
You must not use any part of the content on our site for commercial purposes without
obtaining a licence to do so from us or our licensors.
If you print off, copy or download any part of our site in breach of these terms of use, your
right to use our site will cease immediately and you must, at our option, return or destroy any
copies of the materials you have made.

NO RELIANCE ON INFORMATION


The content on our site is provided for general information only. It is not intended to amount
to advice on which you should rely. You must obtain professional or specialist advice before
taking, or refraining from, any action on the basis of the content on our site.

Although we make reasonable efforts to update the information on our site, we make no
representations, warranties or guarantees, whether express or implied, that the content on our
site is accurate, complete or up-to-date.

LIMITATION OF OUR LIABILITY


Nothing in these terms of use excludes or limits our liability for death or personal injury
arising from our negligence, or our fraud or fraudulent misrepresentation, or any other
liability that cannot be excluded or limited by English law.
To the extent permitted by law, we exclude all conditions, warranties, representations or other
terms which may apply to our site or any content on it, whether express or implied.
We will not be liable to any user for any loss or damage, whether in contract, tort (including
negligence), breach of statutory duty, or otherwise, even if foreseeable, arising under or in
connection with:
 use of, or inability to use, our site; or
 use of or reliance on any content displayed on our site.
If you are a business user, please note that in particular, we will not be liable for:
 loss of profits, sales, business, or revenue;
 business interruption;
 loss of anticipated savings;
 loss of business opportunity, goodwill or reputation; or
 any indirect or consequential loss or damage.
If you are a consumer user, please note that we only provide our site for domestic and private
use. You agree not to use our site for any commercial or business purposes, and we have no
liability to you for any loss of profit, loss of business, business interruption, or loss of
business opportunity.
We will not be liable for any loss or damage caused by a virus, distributed denial-of-service
attack, or other technologically harmful material that may infect your computer equipment,
computer programs, data or other proprietary material due to your use of our site or to your
downloading of any content on it, or on any website linked to it.
We assume no responsibility for the content of websites linked on our site. Such links should
not be interpreted as endorsement by us of those linked websites. We will not be liable for
any loss or damage that may arise from your use of them.

THIRD PARTY LINKS AND RESOURCES IN OUR SITE


Where our site may contain links to other sites and resources provided by third parties, these
links are provided for your information only.
We have no control over the contents of those sites or resources.


APPLICABLE LAW


If you are a consumer, please note that these terms of use, its subject matter and its formation,
are governed by English law. You and we both agree to that the courts of England and Wales
will have non-exclusive jurisdiction. However, if you are a resident of Northern Ireland you
may also bring proceedings in Northern Ireland, and if you are resident of Scotland, you may
also bring proceedings in Scotland.
If you are a business, these terms of use, its subject matter and its formation (and any non-
contractual disputes or claims) are governed by English law. We both agree to the exclusive
jurisdiction of the courts of England and Wales.


CONTACT US


To contact us, please email enquiries@pureenergysolutions.co.uk
Thank you for visiting our site.

Private Policy

Pure Energy Solutions Ltd is an Energy broker offering Utility services and consultancy for
Business.
We are registered in England and Wales under registration number 11522506, and our
registered office is at Kemp House, 160 City Road, London, EC1V 2NX
Sections
1. Introduction
2. How we use your personal data
3. Providing your personal data to others
4. International transfers of your personal data
5. Safeguarding, retaining and deleting personal data
6. Your rights
7. About cookies
8. Applicant privacy notice

9. Amendments
10. Data protection officer
1. Introduction
1.1       We are committed to safeguarding the privacy of our clients, potential clients,
suppliers or other parties.
1.2       This policy applies where we are acting as a data controller with respect to the
personal data of our clients, potential clients, suppliers or other parties whose data we may
collect in the normal course of business; in other words, where we determine the purposes
and means of the processing of that personal data where:
1. Processing is necessary to meet contractual obligations entered into by the data
subject
2. Processing is necessary to comply with legal obligations of the controller
3. Processing is for the purposes of legitimate interests pursued by the controller
1.3       We will ask you to consent to our use of cookies in accordance with the terms of the
Privacy & Cookie policies when you visit our website.
1.4       Our website incorporates privacy controls which affect how we will process your
personal data. By using the privacy controls, you can specify whether you would like to
receive direct marketing communications and limit the publication of your information.
1.5       In this policy, “we”, “us” and “our” refer to Pure Energy Solutions Ltd.
Privacy Controls
By using the privacy controls, you can request access to your information and specify how
we are able to contact you.
2. How we use your personal data
2.1       In this Section we have set out:
1. the general categories of personal data that we may process;
2. the purposes for which we may process personal data; and
3. the legal bases of the processing.
2.2       We may process data about your use of our website and services (“website usage
data”). The usage data may include:
1. your IP address;
2. geographical location;
3. browser type and version;
4. operating system;
5. referral source;

6. length of visit;
7. page views and;
8. website navigation paths
As well as information about the timing, frequency and pattern of your service use.
This website usage data may be processed for the purposes of analysing the use of the
website and services. The legal basis for this processing is our legitimate interests, namely
monitoring and improving our website experience and services.
2.3       We may process your account data (“account data”). The account data may include
your name and email address. The account data may be processed for the purposes of
operating our website, providing our services, ensuring the security of our website and
services, maintaining back-ups of our databases and communicating with you. The legal basis
for this processing is the performance of a contract between you and us and/or taking steps, at
your request, to enter into such a contract.
2.4       We may process your personal data that are provided in the course of the use of our
services (“service data”). The service data may be processed for the purposes of operating our
website, providing our services, ensuring the security of our website and services,
maintaining back-ups of our databases and communicating with you. The legal basis for this
processing is the performance of a contract between you and us and/or taking steps, at your
request, to enter into such a contract.
2.5       We may process information contained in any enquiry you submit to us regarding
goods and/or services (“prospect data”). The data may be processed for the purposes of
offering, marketing and selling relevant goods and/or services to you. The legal basis for this
processing is consent.
2.6       We may process data sourced from a 3rd party supplier (“prospect data”), relating to
an individual that has an interest in buying energy and managing their energy effectively. The
data may be processed for the purposes of offering, marketing and selling relevant goods
and/or services. Individuals associated with energy spend within businesses have an
expectation that Pure Energy Solutions Ltd will communicate with them – offering to provide
value through Pure Energy Solutions’ products and services. The legal basis for this
processing is our legitimate interests, namely as a third-party intermediary for business
utilities and energy Services, Pure Energy Solutions will contact business within the UK in
order to provide energy management, broker energy procurement and associated services for
their business needs.
2.7       We may process information relating to transactions, including purchases of goods
and services, that you enter into with us and/or through our website (“transaction data”). Our
website provides price comparison services for energy. We will collect transaction data from
you when you access our price comparison services. The transaction data may include your
contact details and the transaction details. The transaction data may be processed for the
purpose of supplying the purchased goods and services and keeping proper records of those
transactions. The legal basis for this processing is the performance of a contract between you
and us, to provide you with a realistic indication of prices available to you and/or taking
steps, at your request, to enter into such a contract and our legitimate interests, namely our
interest in the proper administration of our website and business.

When you access our price comparison services via our website, we may use your contact
details to call or email you about your quote and advise you of alternative products and
services that may be suitable for you.  You can opt-out of this service at any time by clicking
on this link, which will allow you to manage your contact preferences.
Manage your data
2.8       We may process your personal data that are provided in the course of employment
(“employee data”) details are contained within its own privacy notice.
2.9       We may process your personal data that are provided in the course of a job
application (“applicant data”) in line with our recruitment process. Further details can be
found in our applicant privacy notice.
2.10       We may process information that you provide to us for the purpose of subscribing to
our email notifications and/or newsletters (“marketing data”). The data may be processed for
the purposes of sending you the relevant notifications and/or newsletters. The legal basis for
this processing is consent
2.11       We may process information contained in or relating to any communication that you
send to us (“correspondence data”). The correspondence data may include the communication
content and metadata associated with the communication. Our website will generate the
metadata associated with communications made using the website contact forms. The
correspondence data may be processed for the purposes of communicating with you and
record-keeping. The legal basis for this processing is our legitimate interests, namely the
proper administration of our website and business and communications with users.
2.12       We may process any of your personal data identified in this policy where necessary
for the establishment, exercise or defence of legal claims, whether in court proceedings or in
an administrative or out-of-court procedure. The legal basis for this processing is our
legitimate interests, namely the protection and assertion of our legal rights, your legal rights
and the legal rights of others.
2.13     We may process any of your personal data identified in this policy where necessary
for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining
professional advice. The legal basis for this processing is our legitimate interests, namely the
proper protection of our business against risks.
2.14     In addition to the specific purposes for which we may process your personal data set
out in this Section, we may also process any of your personal data where such processing is
necessary for compliance with a legal obligation to which we are subject, or in order to
protect your vital interests or the vital interests of another natural person.
2.15    Please do not supply any other person’s personal data to us, unless we prompt you to
do so.
3. Providing your personal data to others

3.1       We may disclose your personal data to any member of our group of companies (this
means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as
reasonably necessary for the purposes, and on the legal bases, set out in this policy.
3.2       We may disclose your personal data to a regulatory authority (such as Ofgem) or the
police in the course of meeting a supply licence requirement or in matters relating to fraud
prevention, detection or other legal concerns.
3.3       We may disclose your personal data to our insurers and/or professional advisers
insofar as reasonably necessary for the purposes of obtaining or maintaining insurance
coverage, managing risks, obtaining professional advice, or the establishment, exercise or
defence of legal claims, whether in court proceedings or in an administrative or out-of-court
procedure.
3.4       We may disclose personal data to our suppliers or subcontractors insofar as
reasonably necessary for the performance of a contract between you and us and/or taking
steps, at your request, to enter into such a contract. When using our online price comparison
service, we provide your personal information to the suppliers whose products and services
are listed on our websites and apps to help them provide quotes and to carry out your switch.
When you buy products or services from these suppliers, their own privacy policies will
apply to how they use your personal information.
3.5       In addition to the specific disclosures of personal data set out in this Section, we may
disclose your personal data where such disclosure is necessary for compliance with a legal
obligation to which we are subject, or in order to protect your vital interests or the vital
interests of another natural person. We may also disclose your personal data where such
disclosure is necessary for the establishment, exercise or defence of legal claims, whether in
court proceedings or in an administrative or out-of-court procedure.
4. International transfers of your personal data
In this Section, we provide information about the circumstances in which your personal data
may be transferred to countries outside the European Economic Area (EEA).
4.1       We and our other group companies have offices and facilities in the United Kingdom
& Hungary. The UK is within the EEA at present and will be until we leave the EU in March
2019. Hungary is within the EEA.
4.2       You acknowledge that personal data that you submit for publication through our
website or services may be available, via the internet, around the world. We cannot prevent
the use (or misuse) of such personal data by others.
5. Safeguarding, retaining and deleting personal data
This Section sets out our data safeguarding and retention policies and procedure, which are
designed to help ensure that we comply with our legal obligations in relation to the retention
and deletion of personal data.
5.1      Safeguarding protocols:

1. Personal Data is kept to an absolute minimum, we do not hold any data that is not
required to support the legitimate Interest of our business and those of our clients
2. Data as a default will be encrypted and transferred securely when in transit
3. The Physical environment is secured with controlled, limited access via a card pass
for just those with authorized access
4. Access to applications and sets of data is controlled by managed rights
5. Firewall and antivirus / malware software are deployed
6. Obfuscation and Anonymisation techniques are used where possible
7. Data Retention and Destruction policies are in place
8. Removal of personal data capabilities are provided
9. Data Breach policy and procedures are in place
5.2       Personal data that we process for any purpose or purposes shall not be kept for longer
than is necessary for that purpose or those purposes.
5.3       We will retain your personal data as follows:
1. ‘Website usage data’ is retained for 2 years.
2. ‘Account data’ is retained as part of ongoing business with active clients. Pure Energy
Solutions also retains ‘account data’ for 6 years for terminated clients to comply with
financial legislation.
3. ‘Service data’ is retained as part of ongoing business with active clients. Pure Energy
Solutions also retains ‘service data’ for 6 years for terminated clients to comply with
financial legislation.
4. ‘Prospect data’ is retained as part of ongoing business with active clients.  Pure
Energy Solutions also retains ‘prospect data’ for 6 years for terminated clients as it is
in Pure Energy Solutions’s legitimate interests, namely the proper defense of the
business against possible litigation. This includes but is not limited to fraud.
5. ‘Transaction data’ is retained as part of ongoing business with active clients. Pure
Energy Solutions Ltd also retains ‘transaction data’ for 6 years for terminated clients
to comply with financial legislation.
6. ‘Marketing data’ is retained as part of ongoing business with active clients. Pure
Energy Solutions Ltd also retains ‘marketing data’ for 2 years for non-client contacts.
7. ‘Correspondence data’ in not retained beyond exit.
8. ‘Employee data’ is retained for up to 7 years, to comply with our legal obligation
details are contained within our employee privacy notice.
5.4       Notwithstanding the other provisions of this Section, we may retain your personal
data where such retention is necessary for compliance with a legal obligation to which we are
subject, or in order to protect your vital interests or the vital interests of another natural
person.

6. Your rights
6.1       In this Section, we have summarised the rights that you have under data protection
law. Some of the rights are complex, and not all of the details have been included in our

summaries. Accordingly, you should read the relevant laws and guidance from the regulatory
authorities for a full explanation of these rights.
6.2       Your principal rights under data protection law are:
1. the right to access;
2. the right to rectification;
3. the right to erasure;
4. the right to restrict processing;
5. the right to object to processing;
6. the right to data portability;
7. the right to complain to a supervisory authority; and
8. the right to withdraw consent.
6.3       You have the right to confirmation as to whether or not we process your personal data
and, where we do, access to the personal data, together with certain additional information.
That additional information includes details of the purposes of the processing, the categories
of personal data concerned and the recipients of the personal data. Providing the rights and
freedoms of others are not affected, we will supply to you a copy of your personal data. The
first copy will be provided free of charge, but additional copies may be subject to a
reasonable fee. You can request access your personal data by emailing your request to
finance@pureenergysolutions.co.uk
6.4       You have the right to have any inaccurate personal data about you rectified and,
taking into account the purposes of the processing, to have any incomplete personal data
about you completed.
6.5       In some circumstances you have the right to the erasure of your personal data without
undue delay. Those circumstances include:
1. The personal data are no longer necessary in relation to the purposes for which they
were collected or otherwise processed;
2. you withdraw consent to consent-based processing;
3. you object to the processing under certain rules of applicable data protection law;
4. the processing is for direct marketing purposes;
5. and the personal data have been unlawfully processed.
However, there are exclusions of the right to erasure. The general exclusions include where
processing is necessary:
1. for exercising the right of freedom of expression and information;
2. for compliance with a legal obligation;
3. or for the establishment, exercise or defence of legal claims.
6.6       In some circumstances you have the right to restrict the processing of your personal
data. Those circumstances are: you contest the accuracy of the personal data; processing is
unlawful but you oppose erasure; we no longer need the personal data for the purposes of our
processing, but you require personal data for the establishment, exercise or defence of legal
claims; and you have objected to processing, pending the verification of that objection.
Where processing has been restricted on this basis, we may continue to store your personal

data. However, we will only otherwise process it: with your consent; for the establishment,
exercise or defence of legal claims; for the protection of the rights of another natural or legal
person; or for reasons of important public interest.
6.7       You have the right to object to our processing of your personal data on grounds
relating to your particular situation, but only to the extent that the legal basis for the
processing is that the processing is necessary for: the performance of a task carried out in the
public interest or in the exercise of any official authority vested in us; or the purposes of the
legitimate interests pursued by us or by a third party. If you make such an objection, we will
cease to process the personal information unless we can demonstrate compelling legitimate
grounds for the processing which override your interests, rights and freedoms, or the
processing is for the establishment, exercise or defence of legal claims.
6.8       You have the right to object to our processing of your personal data for direct
marketing purposes (including profiling for direct marketing purposes). If you make such an
objection, we will cease to process your personal data for this purpose.
6.9       You have the right to object to our processing of your personal data for scientific or
historical research purposes or statistical purposes on grounds relating to your particular
situation, unless the processing is necessary for the performance of a task carried out for
reasons of public interest.
6.10     To the extent that the legal basis for our processing of your personal data is:
1. consent; or
2. that the processing is necessary for the performance of a contract to which you are
party or in order to take steps at your request prior to entering into a contract, and
such processing is carried out by automated means, you have the right to receive your
personal data from us in a structured, commonly used and machine-readable format.
However, this right does not apply where it would adversely affect the rights and
freedoms of others.
6.11     If you consider that our processing of your personal information infringes data
protection laws, you have a legal right to lodge a complaint with a supervisory authority
responsible for data protection. You may do so in the EU member state of your habitual
residence, your place of work or the place of the alleged infringement.
6.12     To the extent that the legal basis for our processing of your personal information is
consent, you have the right to withdraw that consent at any time. Withdrawal will not affect
the lawfulness of processing before the withdrawal.
6.13     You may exercise any of your rights in relation to your personal data by written
notice to us, by email or verbally in most cases, in addition to the other methods specified in
this Section.
Privacy Controls
By using the privacy controls, you can request access to your information and specify how
we are able to contact you.

7. About cookies
7.1       A cookie is a file containing an identifier (a string of letters and numbers) that is sent
by a web server to a web browser and is stored by the browser. The identifier is then sent
back to the server each time the browser requests a page from the server.
7.2       Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie
will be stored by a web browser and will remain valid until its set expiry date, unless deleted
by the user before the expiry date; a session cookie, on the other hand, will expire at the end
of the user session, when the web browser is closed.
7.3       Cookies do not typically contain any information that personally identifies a user, but
personal information that we store about you may be linked to the information stored in and
obtained from cookies.
Cookie Policy
Most browsers automatically accept cookies. You can set your browser options so that you
will not receive cookies and you can also delete existing cookies from your browser.
However, you may find that some parts of the site will not function properly if you disable
cookies.
If you’d like to learn more about cookies and how to manage them please view our Cookie
Policy.
8. Applicant privacy notice
As part of any recruitment process, Pure Energy Solutions Ltd collects and processes
personal data relating to job applicants. Pure Energy Solutions Ltd is committed to being
transparent about how it collects and uses that data and to meeting its data protection
obligations.
9. Amendments
9.1       We may update this policy from time to time by publishing a new version on our
website.
9.2       You should check this page occasionally to ensure you are happy with any changes to
this policy.
9.3       We may notify you of changes to this policy by email.
10. Data protection officer
10.1     Our data protection officer’s contact details are:
Jordan Morley

Email: jordan.morley@pureenergysolutions.co.uk
10.2     If you have a concern regarding how we handle your personal data then we would
request that you inform us about it first so that we can work with you in an effort to resolve it.
10.3     If you are not satisfied with the resolution you can raise a complaint directly with the
Information Commissioners Office (ICO) The ICO will take steps to address this concern and
will in turn offer guidance and support to ourselves to ensure we take corrective steps to
resolving the issue.
This policy was created using a template from SEQ Legal (https://seqlegal.com).