Privacy Policy

At Huddle Utilities Ltd, trading as Squiggle Energy (“Squiggle Energy”, “Squiggle”, “we”, or “us”), we are committed to protecting and respecting the privacy of your personal data. This privacy notice explains how your data is collected, used, transferred, and disclosed by Squiggle Energy. It applies to data collected when you use our websites, iOS, and Android applications, when you interact with us through social media, email, or phone, or when you participate in our competitions or events. It also applies to the extent that someone has nominated you through our "refer a friend" function on your behalf.

It covers:

• The personal data we collect
• How we collect your data
• How we use your data
• Marketing preferences, adverts, and cookies
• If you have requested a quote from our website and you have not opted out of receiving marketing communications from us
• Links to other websites and third parties
• How we share your data
• Your rights
• Changes to this privacy notice
• How to contact us

This privacy policy applies to Squiggle Energy, including TruEnergy each registered at Gable House, 239 Regents Park Road, London, England, N3 3LF (collectively referred to as "Squiggle", "Squiggle Energy", "we", "us", and "our" in this privacy notice) is the controller and responsible for your personal data collected through the www.squiggle.energy website (the "Website").

Details of our Data Protection Officer responsible for overseeing questions in relation to this privacy notice and our details are set out in the "How to Contact Us" section at the end of this notice.

We take the protection of your personal data seriously and will process your personal data fairly, lawfully, and transparently. This privacy notice describes the personal data we are collecting about you and how it is used. We will only collect and use your personal data for the following purposes:

• fulfill your contract(s)
• communicate with you following a "refer a friend" nomination
• keep you up to date with the latest offers, updates, and news
• give you a better experience
• help us to make our marketing more relevant to you and your interests
• improve our services
• meet our legal responsibilities

We have appropriate organisational safeguards and security measures in place to protect your data from being accidentally lost, used, or accessed in an unauthorised way, altered or disclosed.

The communication between your browser and our website uses a secure encrypted connection wherever your personal data is involved.

We require any third party who is contracted to process your personal data on our behalf to have security measures in place to protect your data and to treat such data in accordance with the law.

In the unfortunate event of a personal data breach, we will notify you and any applicable regulator when we are legally required to do so.

Personal data means any information about an individual from which that person can be identified. It does not include anonymised data, where the identity and identifying information have been removed.

While our website is designed for a general audience, we will not knowingly collect any data from individuals under the age of 18 or sell products to children. If you are under the age of 18, you are not permitted to use or submit your data to the website.

The following groups of personal data are collected:

• Identity Data includes information such as first name, last name, title, date of birth, personal description, photo, and gender.
• Contact Data includes information such as email address, billing address, delivery address, location, country, telephone number, household ID number, and social media id (if you log in by social media).
• Financial Data includes information such as payment card details and bank accounts.
• Transaction Data includes information such as details of your purchases and the fulfillment of your purchased products or services (such as basket number, order number, subtotal, title, currency, discounts, type of contract, product number, single item price, category, tax, etc.); payments to and from you and details of other products and services you have obtained from us, correspondence or communications with you in respect of your orders, and details of any rewards and bonuses awarded.
• Technical Data includes information such as details of the device(s) you use to access our services, your internet protocol (IP) address, login data, your username and password, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform.
• Profile Data includes information such as purchases made by you, product interests, preferences, feedback, and survey responses.
• Usage Data includes information such as: how and when you use our website/app, how you moved around it, what you searched for; website/portal performance statistics, traffic, location, weblogs, and other communication data; details of any other Squiggle Energy products and services used by you.
• Marketing and Communications Data includes information such as your preferences in receiving marketing from us and our third parties.
• Smart meter data includes the information sent to us, where we collect consumption information directly from your smart reader, which is used to generate accurate bills from your energy usage. Consumption information may also be used to analyse information for usage graphs and reports which is accessible to you through your tenant portal via www.squiggle.energy. As well as using information from your smart meters in order to develop new products and services.

Financial Data: Please note that all payment details are not directly stored by Squiggle Energy for compliance reasons and any information regarding bank details or payment details entered on our website is done via using a secure encrypted connection.

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 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 may collect personal data about you in the following ways:

(a) Direct interactions – you may give us your Identity, Contact, Financial, Transaction, Profile, and Marketing and Communications data (as described above) by filling in forms, entering information online, or by corresponding with us by post, phone, email, telephone or otherwise. This includes personal data you provide, for example, when you:

• Create an account or purchase products or services on our website;
• Subscribe to our newsletter, discussion boards, and social media sites;
• Enter a competition;
• Join the Squiggle Energy Brand Ambassador program;
• Complete a voluntary market research survey;
• Contact us with an inquiry or to report a problem (by phone, email, social media, or messaging service);
• Use the "refer a friend" function on our website; or
• When you log in to our website via social media;

(b) Automated technologies or interactions – as you interact with our website, we may automatically collect the following types of data (all as described above): Technical Data about your equipment, Usage Data about your browsing actions and patterns, and Contact Data where tasks carried out via our website remain uncompleted, such as incomplete orders or abandoned baskets. We collect this data by using cookies, server logs, and other similar technologies. Please see our Cookie Policy for further details;

(c) Third parties – we may receive personal data about you from various third parties, including:

• Identity and Contact data from another individual when you give your account number for them to use as the unique code to the "refer a friend" function on our website;
• Technical Data from third parties, including analytics providers such as Google. Please see further information in the section entitled "Marketing preferences, adverts, and cookies";
• Technical Data from affiliate networks through whom you have accessed our website;
• Identity and Contact Data from social media platforms when you log in to our website using such social media platforms;
• Identity and Contact data from third parties, including organisations (including law enforcement agencies), associations, and groups, who share data for the purposes of fraud prevention and detection and credit risk reduction; and
• Contact, Financial and Transaction Data from providers of technical, payment, and delivery services.

Your personal data is used by Squiggle Energy to support a range of different activities, together with the types of data used and the legal bases we rely on when processing them, including where appropriate, our legitimate interests. Please be aware that we may process your personal data using more than one lawful basis, depending on the specific activity involved.

We process and share your account performance, invoice history, and missed payment data with Credit Reference Agencies and third-party debt recovery agents. This is necessary for our Legitimate Interests in managing commercial risk, protecting our business from financial default, and promoting responsible lending within the wider utility market. 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.

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 we wish 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. We may process personal data without your consent, in compliance with the above rules, where this is required or permitted by law. If you have any questions about how Squiggle Energy uses any of your personal data, please contact us at DPO@huddle.uk.com.

Sharing customer data within our group (specifically to Tru Energy) to facilitate ongoing account management, billing, payment handling, and the transfer and recovery of outstanding debts (including where rights under your contract are novated or transferred).

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

We may send you marketing communications and promotional offers:

• if you have opened an account with us or purchased our services or products from us, or registered for a promotion or event, and you have not opted out of receiving that marketing (in accordance with your preferences, as explained below);
• by email, if you have signed up for email newsletters;
• if you have provided us with your details when you entered a competition and you have consented to receive such marketing (in accordance with your preferences, as explained below).

We may use your Identity, Contact, Technical, Transactional, Usage, Profile Data, and Marketing and Communications Data to form a view on what we think you may like, or what may be of interest to you, and to send you details of products and offers which may be relevant for you.

We will ask you for your preferences in relation to receiving marketing communications by email, post, SMS, and other communication channels.

In respect of third-party marketing communications, we will obtain your express opt-in consent before we share your personal data with any third party for marketing purposes.

You will always have full control of your marketing preferences. If you do not wish to continue receiving marketing information from us (or any third party, if applicable) at any time:

• you can unsubscribe or "opt-out" by using the unsubscribe button and following the link included in the footer of any marketing email.

We will process all opt-out requests as soon as possible, but please note that due to the nature of our IT systems and servers it may take a few days for any opt-out request to be implemented.

Cookies

Our website uses cookies to differentiate you from other users of our website and to keep track of your visits. This enables us to provide the best customer experience when you visit our website as well as enabling us to make appropriate changes to your website to improve the overall experience. They also help us and our advertising networks to make advertising relevant to you and your interests.

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For detailed information on the cookies which we and our third-party providers use and the reasons why we use them, please refer to our Cookie Policy.

Online ads

We use online advertising to keep you aware of what we're up to and to help you find our products. Like many companies, we may target Squiggle Energy banners and ads to you when you use other websites and apps, based on your Contact, Technical, Usage, and Profile Data.

We do this using a variety of digital marketing networks and ad exchanges, and a range of advertising technologies such as web beacons, pixels, ad tags, cookies, and mobile identifiers, as well as specific services offered by some sites and social networks.

Our use of analytics and targeted advertising tools

We use a range of analytics and targeted advertising tools to display relevant website content on our website and online advertisements on other websites and apps (as described above) to you, deliver relevant content to you in marketing communications (where applicable), and to measure the effectiveness of the advertising provided. For example, we use tools such as Google Analytics to analyse Google's interest-based advertising data and/or third-party audience data (such as age, gender, and interests) to target and improve our marketing campaigns, marketing strategies, and website content. We may also use tools provided by other third parties, such as Facebook, AdTraction, and Instagram to perform similar tasks, using your Contact, Technical, Usage, and Profile Data.

In order to opt-out of targeted advertising, you need to disable your "cookies" in your browser settings (see Cookie Policy for details) or opt out of the relevant third-party Ad Settings. For example, you can opt-out of the Google Display Advertising Features. As an added privacy measure, you can also use the Digital Advertising Alliance (which includes companies such as Google, and Facebook) provides a tool called WebChoices that can perform a quick scan of your computer or mobile devices, and find out which participating companies have enabled customised ads for your browser, and adjust your browser preferences accordingly. If you would like any further information about the data collected by these third parties or the way in which the data is used, please contact us.

Our website may include links to and from the websites of our partner networks, advertisers, and affiliates, or to social media platforms. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to their websites.

Personal, transactional, and billing data is shared with Tru Energy Limited. Data is shared to enable account setup, meter administration, billing, payment processing, customer service, debt collection, and debt recovery.

We may disclose and share your personal data with the parties set out below:

• where you have consented for us to do so. For example, if you have consented to receive marketing materials from third parties, or in respect of third parties (including co-branded or jointly promoted) products and services, we may pass your data on to the relevant third parties for the purpose of sending you such marketing communications;
• to business partners, suppliers, sub-contractors and other third parties that we use in connection with the running of our business for the purposes set out in the section "How we use your data", such as:
• third-party service providers that we engage to provide IT systems and software, and to host our website;
• third party payment processing services (including GoCardless, Global Payments — please see the T&C's on https://gocardless.com/privacy/ and https://www.globalpayments.com/en-gb/privacy-statement for more information) to process your payment to us. Squiggle Energy does not store your payment information. Your payment details are provided to the payment processing service you have selected, which is required to comply with applicable regulations and data protection laws. Please refer to the privacy policy of the relevant provider for details of how they process your personal data;
• services and to provide marketing and advertising services;
• our engineers and other subcontractors install meter readers, broadband devices, and other relevant goods;
• debt collectors where we have a legitimate interest to collect sums of money owed to us for our products and/or services;
• credit reference agencies to help us assess your ability to pay for your energy bills;
• our affiliates and partners, including our white label partners to the extent necessary to enable us to deliver our services to us;
• analytics and search engine providers that assist us in the improvement and optimisation of our website;
• affiliate networks through whom you have accessed our website;
• to any third party 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;
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation; or
• to our professional advisers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.

The personal data we collect from you may be transferred to and stored at, destinations outside the European Economic Area ("EEA") using legally-provided mechanisms to lawfully transfer data across borders. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfillment of your order, the processing of your payment details, and the provision of support services. We will take all steps necessary to ensure that your data is treated securely and in accordance with this privacy notice.

Whenever we transfer personal data outside the EEA, we will ensure a similar degree of protection is afforded to it by ensuring appropriate safeguards, as required by law, are in place. This may include using specific contractual clauses approved by the European Commission which give personal data the same protection as it has in Europe.

Please contact us if you want further information on the countries to which we may transfer personal data and the specific mechanism used by us when transferring your personal data outside the EEA.

You have several rights under the data privacy legislation. This includes, under certain circumstances the right to

• request access to your personal data
• request correction of your personal data
• request erasure of your personal data
• request restriction of processing of your personal data
• request the transfer of your personal data
• object to the processing of your personal data

Brief details of each of these rights are set below. If you wish to exercise these rights please email us at DPO@huddle.uk.com.

Request access to your personal data

You have the right to obtain a copy of the personal data we hold about you and certain information relating to our processing of your personal data.

Request correction of your personal data

You are entitled to have your personal data corrected if it is inaccurate or incomplete. You can update your personal data at any time by logging into your account and updating your details directly, or by emailing us at DPO@huddle.uk.com.

Request erasure of your personal data

This enables you to request that Squiggle Energy delete your personal data, where there is no good reason for us to continue to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Request restriction of processing of your personal data

You have a right to ask Squiggle Energy to suspend the processing of your personal data in certain scenarios, for example, if you want us to establish the accuracy of the data, or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Where the processing is restricted, we are allowed to retain sufficient information about you to ensure that the restriction is respected in the future.

Request the transfer of your personal data

You have the right to obtain a digital copy of your personal data or request the transfer of your personal data to another company. Please note though that this right only applies to automated data which you initially provided consent for us to use or where we used the data to perform a contract with you.

Object to processing of your personal data

You have the right to object to the processing of your personal data where we believe we have a legitimate interest in processing it (as explained above). You also have the right to object to our processing of your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your data which override your rights and freedoms.

Right to lodge a complaint

If you have any concerns or complaints regarding the way in which we process your data, please email us directly at DPO@huddle.uk.com. You also have the right to make a complaint to the ICO (the data protection regulator in the UK). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please do contact us in the first instance.

From time to time we may change this privacy notice. If there are any significant changes we will post updates on our website, and applications or let you know by email.

Your energy is supplied by Tru Energy Limited. When you apply, we share the details you give us with Tru Energy so they can set up and manage your supply.

Tru Energy will carry out a credit check with credit reference agencies to verify your identity and decide what payment terms to offer you. This search will be recorded on your credit file. Tru Energy will also share information about you and how you manage your account — including payments, arrears and defaults — with credit reference agencies on an ongoing basis. Those agencies may share it with other organisations, and this can affect your ability to obtain credit in future.

Full details of what the credit reference agencies do with your data, where it comes from, how long they keep it and your rights over it are set out in the Credit Reference Agency Information Notice: www.transunion.co.uk/crain

We welcome feedback and are happy to answer any questions you may have about your data.

Please send any questions, comments, or requests for more information to our nominated representative and Data Protection, who can be contacted at DPO@huddle.uk.com.