Low Carbon Hub is committed to protecting your privacy and takes its responsibilities regarding the security of stakeholder information very seriously. This Privacy Statement explains what personal data we collect about you, how and why we use it, who we disclose it to, and how we protect your privacy.

1. Who is responsible for your data

Our privacy statement applies to the personal data that Low Carbon Hub collects and uses.

References in this Privacy Statement to “Low Carbon Hub ”, “we”, “us” or “our” mean Low Carbon Hub CIC (a company registered in England and Wales with registration no 7583663) and The Low Carbon Hub IPS Limited (Registration no. 31903R). The registered office for both companies is ​Holywell House, Osney Mead, Oxford, OX2 0ES. We control the ways your personal data are collected and the purposes for which your personal data are used by Low Carbon Hub and are the “data controller” for the purposes of the UK Data Protection Act 1998.

Both companies are on the ICO Data Protection Register; The Low Carbon Hub CIC Registration Number A1072250 and The Low Carbon Hub IPS Limited Registration Number A1072251.

2. Purpose and lawful basis for processing your data

We will only use your information for the purpose it was collected for, or for a very similar purpose, under the guidelines of legitimate business interests.

We have two purposes for processing your personal data:

• To sell our products and services to you and to administer our ongoing relationship with you.  This purpose allows Low Carbon Hub to lawfully process your data for legitimate interests (GDPR 6F) and our legal obligations (GDPR 6C) to the relevant tax and revenue authorities.
• To inform and engage with you about community energy and our products and services. This purpose allows Low Carbon Hub to seek your consent to process your data for communication, education and marketing purposes (GDPR 6A). Without your explicit consent, Low Carbon Hub will not process your data for this purpose.

We will never sell your personal data or share it with any third parties to market or sell products to you.

The purpose and lawful basis for processing your data may change from time to time and this policy will be updated to reflect any changes.

3. Consent

We will always ask your consent to collect your data. Here are some of the ways we’re currently collecting your consent.

Low Carbon Hub Newsletter

Your consent to receive the newsletter is an explicit action. We will not use defaulted opt-in checkboxes or include your personal data for communication and marketing purposes where you have asked only for a transactional email.

We use MailChimp as the platform to manage our newsletter communications. By confirming that you wish to receive our email communications, which include important information on our projects and share offer opportunities, you acknowledge that the contact details you supply to us will be stored in MailChimp.

You can read their Privacy Statement and Terms for more information.

If you wish to withdraw your consent from receiving these newsletter communications, you can either unsubscribe directly via a link at the bottom of an email sent to you contact us directly to unsubscribe you.

OxFutures

When you register with OxFutures through the website or via email, you are confirming that the partners within the project (Oxford Brookes University and the Low Carbon Hub) have your permission to send you:

• Regular project updates, news bulletins and best practice case studies and newsletters
• Networking and R&D opportunities with other businesses at project workshops and seminars
• The opportunity to receive a minimum of 12hrs free business improvement support.

We will also provide your contact details to trusted third parties, such as our Grant Contract Administrators at the Ministry of Housing Communities & Local Government to fulfil our grant funding reporting requirements. It is a funding condition that we measure the impact and success of the project and a third party may contact you for this purpose, but you are under no obligation to take part.

If OxFutures partners have other energy efficiency or innovation services related to the support we are offering through our programme, we may send you information about this.

People’s Power Station

When you submit the form with your details, you are confirming that the Low Carbon Hub has your permission to display information about your green energy project on the People’s Power Station. For generation installations, this includes information about the power it generates, its location and the ownership information submitted. For energy efficiency projects this includes information about the efficiency measures carried out, the energy and CO₂ savings, its location and the ownership information submitted.  

You are also asked for your specific consent for your project to feature on the UK100 Clean Energy map.

We will not be sharing your contact details with UK100 Clean Energy, only the information that is already made public on the People’s Power Station and the meter number, which is used as a unique reference number for your installation’s record by the software.

Cosy Homes Oxfordshire

When you register for Cosy Homes Oxfordshire, and/or fill in the Cosy Homes Oxfordshire survey, you are confirming that the Low Carbon Hub, along with its project partners, has your permission to use information you enter about your home to help provide a whole house plan and access to the Cosy Homes Oxfordshire service. Our project partners are: Low Carbon Hub CIC Community Group Members, the community groups who own a share in the Low Carbon Hub CIC, Parity Projects and RetrofitWorks and their contractors to deliver our retrofit service.

If you Registered for Cosy Homes Oxfordshire during its pilot phase (April 2019 to March 2021) we will only process (including sharing and receiving) your information with the following external organisations or official bodies: the grant provider The Department for Business, Energy and Industrial Strategy (BEIS) and the evaluation consultants they employ, for the purposes of energy efficiency and energy use evaluation and research. The information supplied to BEIS will be limited to:

• Your address
• Type and capacity of energy efficiency measures installed into your property
• Date of when the measures were installed into your property.

The evaluation company will, in addition, be provided with your name and contact details and will only contact you for the purpose of evaluation or improving the service and you are under no obligation to take part in the evaluation when contacted.

Cosy Homes Oxfordshire newsletters

Anyone who chooses to subscribe to our Cosy Homes Oxfordshire newsletter mailing list is added to a list and will be sent a monthly email newsletter.

A representative from each of our community advocate groups is added to a newsletter mailing list. This will be used to send a monthly advocate update, to keep you informed on the progress of Cosy Homes Oxfordshire.

We use MailChimp as the platform to manage our newsletter communications. You can read their Privacy Statement and Terms for more information. 

If you wish to withdraw your consent from receiving this newsletter, you can either unsubscribe directly via a link at the bottom of an email sent to you contact us directly to unsubscribe you.

Project LEO

Smart and Fair Neighbourhood trials 

When you sign up to take part in a Smart and Fair Neighbourhood trial, you are confirming that the Low Carbon Hub can use your details in the way laid out in the trial consent form. This may include sharing your details with project partners and subcontractors. 

These trials form part of Project LEO. We will share anonymised data from the trial with: 

• Project LEO consortium partners as part of our evaluation process. A full list of partners can be seen at project-leo.co.uk  
• Innovate UK and the Department of Business, Energy, and Industrial Strategy as funders of Project LEO – who may also share findings with the wider public when acting on the recommendations made.

As a publicly funded trial, the findings of our trial will be published. We will make all data anonymous in our public reports. We will not include any data which could identify you when discussing our findings, although you may be quoted anonymously.

Smart and Fair Neighbourhood trial newsletter 

All members of the Smart and Fair Neighbourhood (SFN) trial communities will be added to a SFN mailing list. This will be used to keep you informed on the progress of all SFNs in Project LEO. 

We use MailChimp as the platform to manage our newsletter communications. You can read their Privacy Statement and Terms for more information. 

If you wish to withdraw your consent from receiving this newsletter, you can either unsubscribe directly via a link at the bottom of an email sent to you contact us directly to unsubscribe you.

Energy Solutions Oxfordshire (ESOx)

When you register with ESOx through the website or via email, you are confirming that the project partners have permission to use the information you give us about your organisation and premises to allow you to access the ESOx service, including creating a Desktop Diagnosis and/or Feasibility Report. This includes the Low Carbon Hub and the Environmental Information Exchange team at Oxford Brookes, as well as consultants working on their behalf, and BASEE project partner EnergyPro.

You are also confirming that project partners have your permission to send you

• Project updates and bulletins 
• Networking, project workshops and seminars opportunities
• Information about other energy efficiency or innovation services relating to the support we are offering through our programme.

We may also provide your contact details to trusted third parties, such as our Grant Contract Administrators at the Department of Business Energy & Industrial Strategy (BEIS) to fulfil our Boosting Access to SME Energy Efficiency (BASEE) grant funding reporting requirement until July 2021. It is a funding condition that we measure the impact and success of the project and a third party may contact you for this purpose, but you are under no obligation to take part. 

ESOx Sparks newsletter

We use Zoho Campaigns as the secure platform to manage our monthly newsletter communications for those who choose to subscribe. You can read their Privacy Policy for more information on how they manage date. 

If you wish to withdraw your consent from receiving this newsletter, you can either unsubscribe directly via a link at the bottom of an email sent to you, or contact us directly to unsubscribe you.

Reviewing consent

We will keep your given consent(s) on file for a period of up to 6 years from the last change before checking if your consent is still valid. 

At 6 years we will write to you by email with a statement of consent and your current choices. We will then send a reminder email after 30 days if no contact has been received. If this is not responded to then we will take that your granting of consent is still valid.

If you wish to withdraw your consent to the data,  please contact us at info@lowcarbonhub.org or 01865 246099. We’ll get back to you with an initial response in a week and hope to deal with your request within 30 days.

4. Personal data we collect about you

When using the term “personal data” in our Privacy Statement, we mean information that relates to you and allows us to identify you, either directly or in combination with other information that we may hold. Your personal data may include your name, your contact details, information relating to your investment (e.g. shareholding, certificate numbers).

We collect some personal data from you, for example when you invest in us, make a help desk enquiry, receive a grant from us, use our services or contact us. We may also receive your personal data from our suppliers who provide services to you on our behalf, e.g. Ethex, the share purchase platform.  For more information on the parties who may share access to your personal data , please see sections 6 and 12 below.

Categories of data we collect 

We may collect and process the following categories of information about you:

Categories of data we collect and store	For example when we process data for the following purposes
Name and surname; contact details (email address, telephone number, postal address)	When you purchase, or enquire/use, our products and services When your organisation enters into a service contract with us When you or your organisation receives a grant from us When you or your organisation makes a helpdesk query When you attend our events When you create an account on our website (e.g. People’s Power Station) When we undertake market research When you have consented to be included in phone, email or workshop surveys When you subscribe to a newsletter When you sign up to a trial or pilot project.
Bank account details	When you purchase shares in The Low Carbon Hub IPS Limited. When we need to make a payment to you.
Information about your purchases of our products and services	When you purchase such products or services
The communications you exchange with us (for example, your emails, letters, calls, or other messages)	When you contact Low Carbon Hub or you are contacted by us
Your social media account	When you interact with us on social media When we target social media posts
Your posts and messages on social media directed to Low Carbon Hub	When you interact with us on social media
Your feedback	When you reply to our requests for feedback or participate in our stakeholder surveys
Information about how you use our website	When you navigate on our website
Information about your shareholdings	When you purchase shares from The Low Carbon Hub IPS Limited. This could include information about your wishes on death, and holdings held on behalf of children
Information about your renewable project listed on the People’s Power Station. Including type of renewable projects – commissioning date, generation capacity, predicted annual generation, ownership, MSC certification number, Local Authority, Location	When you complete and submit information to be included
Information about your energy efficiency project listed on the Peoples Power Station, including whether an energy audit was carried out, energy efficiency measures carried out and CO2 savings. Information about the fabric of your home and energy use data e.g. house occupancy, home appliances etc.	When you complete and submit information to be included When you sign up to a trial or pilot project

Sensitive personal data

Information that could reveal your racial or ethnic origin, physical or mental health, religious beliefs or alleged commission or conviction of criminal offences is considered “sensitive personal data” under the UK Data Protection Act 1998 and other data protection laws. We do not collect this data.

5. How and why we use your personal data

We use your personal data for the following purposes:

To manage your investment and provide our services to you
When you purchase shares from us, or seek advice, we use your information to perform our services in relation to your investment or enquiry, for example to provide you with information about your investment such as your interest payments or tailor specific help desk advice to your project’s needs.

To communicate with you and manage our relationship with you
Occasionally we may need to contact you by email and/or telephone for administrative or operational reasons, for example if you are an investor or a host organisation.

Please be aware that these communications are not made for marketing purposes and as such, you will continue to receive them even if you opt-out from receiving marketing communications.

We will also use your personal data if we contact you after you have sent us a request, filled in a web form through our website or contacted us on social media.

Your opinion is very important to us, so we may send you an email to seek your feedback.

We will use the communications you exchange with us and the feedback you may provide in order to manage our relationship with you as our stakeholder and to improve our services and experiences for other stakeholders.

We may also collect information on how you use our website, for example which pages of our website you visit most. This information is for internal reporting only.

Trials and learning

When you sign up to a trial, for example through a Project LEO Smart and Fair Neighbourhood trial, we may collect and analyse information about the fabric of your home and your home energy use – when you use electricity and at what times. 

This will help us inform the learning for the trial. The full details of information we will collect will be laid out in the trial consent form. 

To provide statistical information about renewables and energy efficiency in Oxfordshire through the Peoples Power Station and carefully selected partners.

To improve our services, fulfil our administrative purposes and protect our business interests 

The business purposes for which we will use your information include fulfilling our grant funding reporting requirements, accounting, billing and audit, fraud screening, security and legal purposes, statistical and marketing analysis, systems testing, maintenance and development.

To comply with our legal obligations 

For example, our obligation to provide your information to HMRC tax and revenue services.

To inform you about the work of the Low Carbon Hub and products and services 

We may send you marketing communications, if you have indicated that you are happy to receive these, for example when you subscribed to our newsletter through the website or became an investor shareholder and you explicitly agree to receive such communications. 

If you are happy to receive marketing communications, we will provide you with news from us such as new products that you may be interested in or services that you may like.

Please note that we never share your contact details and other personal data with other companies for marketing purposes.

You can choose to opt out from receiving marketing communications at any time, by clicking on the relevant unsubscribe link at the bottom of any marketing related email you may receive from us.  Alternatively, you can call us on 01865-246099 or email us at info@lowcarbonhub.org and ask to be unsubscribed.

6. Security of your personal data

We are committed to taking appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing and against accidental loss, destruction or damage.

The information that you provide to us will be held in our systems, which are located on our premises or those of an appointed third party. We may also allow access to your information by other third parties who act for us for the purposes described in this Privacy statement or for other purposes approved by you. All personal data stored electronically is in secure cloud-based systems and may be processed outside the UK.

The specific information for each provider can be found in the links below:

• Quickbase https://www.quickbase.com/security-and-compliance
• BOX https://www.box.com/legal/privacypolicy
• Mailchimp https://mailchimp.com/legal/privacy/
• Typeform https://admin.typeform.com/to/dwk6gt
• CiviCRM https://civicrm.org/about/privacy-policy

From time to time we may change our service providers and update our Privacy Statement accordingly.

Third parties

As described in this Privacy statement, we may in some instances disclose your personal data to third parties. Where Low Carbon Hub discloses your personal data to a third party, we require that third party to have appropriate technical and organisational measures in place to protect your personal data; however, in some instances we may be compelled by law to disclose your personal data to a third party, such as local police agencies, and have limited control over how it is protected by that party.

We will retain your personal data for as long as we need it in order to fulfil our purposes set out in this Privacy statement, or in order to comply with the law, but for a period no more than 10 years after our relationship with you has ceased.

In the event of a security breach

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, Low Carbon Hub shall promptly assess the risk to your rights and freedoms and if appropriate report this to you.

7. Requesting access to your personal data

You have a right to request access to the personal data that we hold about you. This could include purchase information relating to products and services.

If you have questions in relation to your personal data, please contact us at: info@lowcarbonhub.org with your name and postcode along with an outline of your request. We’ll get back to you with an initial response in a week and hope to deal with your request within 30 days.

8. Right to be forgotten

You have a right to be forgotten and have your personal data erased and / or stop being processed:

• Where the personal data is no longer necessary for the purpose it was collected or processed for;
• We are relying on consent e.g. as a mailing list subscriber and you withdraw consent
• We are relying on legitimate business interests as our basis for processing and you object to our processing of the data, and there is no overriding legitimate reason to continue this processing,
• We are processing the personal data for direct marketing purposes and you object to that processing.

We will not erase your records if we need to maintain your transactional data for our legal obligations to the local tax and revenue authorities (HMRC) and obligatory retention periods for government grants.  We will commit to erase the data once the obligatory retention period is over, e.g. after 7 years for HMRC purposes.

Retention policies of our cloud-based service providers

If we cease the contract with any of our cloud-based service providers, there may be a brief retention period beyond the contract end date.  Details specific to each provider can be found below.

• Quickbase – https://www.quickbase.com/security-and-compliance
• BOX https://www.box.com/legal/privacypolicy
• Mailchimp https://mailchimp.com/legal/privacy/
• Typeform https://admin.typeform.com/to/dwk6gt

• CiviCRM: https://civicrm.org/about/privacy-policy

If you have a request in relation to your personal data, please contact us at: info@lowcarbonhub.org

9. Right to restrict processing

You have a right for your personal data to be stored but not processed. This is achieved through the withdrawal of consent.

If you have questions in relation to your personal data, please contact us at: info@lowcarbonhub.org.

10.  Rights related to automated decision making

Low Carbon Hub does not engage in any automated decision-making processes, i.e. where decisions are made based solely on your data by automated means and without any human involvement.

11. Cookies or other tracking technologies

In order to improve our services and to analyse how visitors use our website, we may use technologies, such as cookies, pixels or tracking software, ie web beacons. Please be aware that in most cases we will not be able to identify you from the information we collect using these technologies.

For example, we use software to monitor customer traffic patterns and website usage to help us develop the design and layout of the website in order to enhance the experience of the visitors to our website. This software does not enable us to collect any personal data. In addition, in order to understand how our customers interact with the emails and the content that we send, we use pixels that allow us to know if the emails we send are opened or if the content of our emails is displayed in text or html form.

We use cookies in our website to monitor how our website is used. Cookies are small pieces of information stored by your browser on your computer’s hard drive. They are commonly used by organisations to improve the user experience of websites. They can be turned off in your browser settings.

12. Sharing your personal data

Your personal data is shared between the companies within our Group, The Low Carbon Hub CIC, The Low Carbon Hub IPS Limited, Low Carbon Hub Sandford Hydro Limited, and Ray Valley Solar Limited.

We may also share some of your personal data with, or obtain your personal data from, the following categories of third parties:

Suppliers providing services to us in order to help us run our business

We may, for example, share your personal data with our Accountants in order to comply with tax and revenue obligations.  We may also disclose your information to the mailing houses who help us distribute information sent by post. 

The Low Carbon Hub very carefully selects our suppliers who process your personal data on our behalf and require that they comply with high security standards for the protection of your personal data.

Authorities

We may disclose your personal data when this is required by the law of any jurisdiction that Low Carbon Hub may be subject to.

Through our website, we provide links to third party websites which are subject to separate privacy policies. Please be aware that this Privacy statement does not apply to such websites and Low Carbon Hub is not responsible for your information that third parties may collect through these websites.

13. Updates to our privacy statement

From time to time we may make changes to this privacy statement.  We will update and publish on our website any new version of this statement.

Last reviewed: 16/09/21

14. Contact information

If you have any questions, comments or requests regarding this Privacy Statement, please contact info@lowcarbonhub.org.

15. How to complain 

If you have any concerns about our use of your personal information, you can make a complaint to us at Low Carbon Hub, Holywell House, Osney Mead, Oxford OX2 0ES or info@lowcarbonhub.org.

You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:           
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire

SK9 5AFHelpline number: 0303 123 1113
ICO website: https://www.ico.org.uk