We know that providing personal information is an act of trust and we take that seriously.
2. In a nutshell
Most of the data we collect and hold relates to Bulb members. However, parts of this policy also apply to non-members, such as people who use the Bulb Store to enquire about goods and services offered there. Data about you is mainly used for the purpose of:
providing your energy (or related products and services)
offsetting your carbon footprint, if you’ve used our Carbon Calculator and signed-up to monthly payments
collecting payments from you for the energy efficiency measures you’ve installed on your premises if you’re involved in the Green Deal Plan
We also use data to make Bulb’s products and services better, and to help us advertise Bulb.
2.1 To supply you with energy and where you use the Bulb store
We gather information about you and your home so we can accurately supply your energy. For example, we need to know your address to supply the right property, and we need to know how much energy you use so we can send you accurate statements.
We may also gather additional information if you buy other goods and services from us or directly from third parties we work with. For example, if you use an electric vehicle and link this to our Bulb app, we may gather real-time data on usage and your vehicle location, to be able to differentiate between home and public charging and apply the appropriate smart charging schedules.
Our affiliates and partners may also supply us with information such as your name and address so we can confirm that we are your energy supplier.
We use Tully and OpenWrks to help members who are struggling to pay. Tully and OpenWrks are separate data controllers, independent of Bulb. If you choose to use Tully’s service, you enter into a contract with both companies directly – you’ll be told about this at the time. Their privacy policies are available to read at the links below. You should make sure you’re familiar with them:
Where necessary, we share information with other organisations such as those listed in section 9 below.
2.2 To offset your carbon footprint
If you use our Carbon Calculator to work out and offset your carbon emissions, we gather information from you so we can work out the size of your carbon footprint and how you can reduce it.
For example, we need to know what sort of transport you use during the week, the sorts of food you eat and how often you fly, so that we can either provide you with advice on how to reduce your carbon footprint or we will provide you with an option to pay to offset your carbon emissions.
2.3 To manage your Green Deal Plan
If you are part of the Green Deal Plan, we gather information about the energy supply at your home, so we can manage your Green Deal Plan.
2.4 To make Bulb better
We collect data on how you use our website, App and other features. We track things like where you click on our site and what features you use. This lets us learn what’s working well and what features we need to improve.
We sometimes share this data in an aggregated form with agencies or partners that are helping us. For example, we might tell a telecommunications partner how many phone calls we get a week.
2.5 To advertise Bulb
We use your data to help grow Bulb and spread renewable energy. If you’re a member of Bulb, we share data with social media, search engines, and other advertising platforms so that we stop asking you to join Bulb, and instead show you content more relevant to you.
We also share aggregated data with agencies that help us with advertising. For example, we might share with an agency how many of our members live in Scotland.
2.6 To communicate with you
In addition to sending you key information about your account by email, from time to time we’ll also send you information about things we think will interest you. If you’re a Bulb energy member, this includes letting you know the carbon emissions you’re avoiding each year by being with Bulb, updates on our referral programme, and reminding you about how you can manage your energy online.
If you sign up to offset your carbon footprint using our Carbon Calculator, this includes letting you know about the carbon reduction projects your money is supporting, telling you about new product updates, and reminding you when it’s been a year since you signed up.
Where necessary, we share your data with organisations that send communications on our behalf. For example, we ask Trustpilot to send invitations to review our service to our energy members and our Carbon Calculator offsetting members.
3. Information we collect from Bulb energy members
3.1 Information you provide us at sign-up
Contact information: such as your name, address, email address, date of birth and telephone number.
Vulnerability information: such as disabilities, age, or health conditions for you or a member of your household. This helps us provide suitable additional services.
Financial information: such as your payment details and financial circumstances. We need your bank details if you want to pay by Direct Debit. If you have difficulty paying our bills, providing details of your circumstances helps us work with you to resolve this.
If you are eligible for the Feed-in Tariff scheme: additional information to confirm your identity (such as a copy of your passport or driving licence, or proof of company registration) and information about your Feed-in Tariff installation (such as a certification document and your installation meter details). We are required to collect this information to comply with Ofgem’s Feed-in Tariff scheme.
4. Information we collect from carbon offsetting members
4.1 Information you provide us at sign-up
Contact information: such as your name and email address.
Carbon emissions information: such as the type of transport you use during the week, the sorts of foods you eat and how often you fly.
Financial information: such as your payment details. Information about your debit or credit card is stored and processed on our behalf by our payment partners Stripe, so you can pay monthly to offset your carbon footprint. You can find more information on how Stripe processes your personal data and your data protection rights by looking at Stripe’s privacy policies.
5. Information we collect while we provide you energy services
Information about your energy supply: such as your meter reference numbers and meter type. This ensures we link you with the right meter and keep industry databases accurate.
Energy you use: such as details of your energy use and your supply start and end dates. If you have a smart meter or Bulb energy monitor we will take consumption data directly from your meter in line with the consents you have given us. We need details of your energy usage so we can send you accurate statements.
Energy you generate: details of energy you generate under the Feed-In Tariff, our Export Tariff or the Smart Export Guarantee. We need this information so we can accurately calculate the payments due to you.
Smart meter information: if you have a smart meter it will transmit data that lets us know that it is safe and operating and recording correctly.
Information from devices: if you connect devices to your Bulb account (for example electric vehicles (EVs), EV chargers, batteries and heat pumps), we will receive details about the device such as make, model and capacity; real-time device data such as power usage, battery level and current state; information about your behaviour such as your chosen thermostat temperature; and, in the case of electric vehicles, mileage and vehicle location. We need this information to be able to connect to these devices and to serve your account (such as smart charging schedules and displaying charging costs on the Bulb app).
Warm Home Discount and Affordable Warmth measures: if you apply for the Warm Home Discount or Affordable Warmth measures, you will be asked for information about any benefits you receive and money you get from employment, to assess your eligibility for assistance. We are required to collect this information to comply with Ofgem’s Warm Home Discount scheme.
6. Information we collect while we provide you energy services or carbon offsetting services
Customer service data: when you get in touch by phone, email, chat or community posts we monitor, record and review those communications so we can provide the best possible service to you, all our energy members and carbon offsetting members, and so we can show evidence of transactions or events.
7. Information provided by others so we can serve your account
Affiliates and partners: when you sign up with Bulb through an affiliate or partner (such as a price comparison website, a telephone sales agency, an events sales agency or door to door agency) for energy services, we are sent your personal information from that partner so we can enter into a contract with you. Where you buy goods or services from third parties that we work with (such as those on our website), we may also receive information relating to this to enable us to provide energy and serve your account. For example, where we display products and services via the Bulb Store, our affiliates and partners may send us details such as your name and address so they can verify that Bulb is your energy supplier. We may also receive information as to what goods and services you have purchased from them. This may be required to calculate related fees, connect devices to supply energy or to otherwise serve your account.
Energy industry partners: metering and debt information can come from other organisations involved in supplying your energy, such as your old supplier and meter operators.
Connected devices: where you want to connect certain devices to your Bulb account (such as electric vehicles (EVs), EV chargers, batteries and heat pumps), we will receive details from the device such as make, model and capacity; real-time device data such as power usage, battery level and current state; information about your behaviour such as your chosen thermostat temperature; and, in the case of electric vehicles, mileage and vehicle location. We need this information to be able to connect to these devices and to serve your account (such as smart charging schedules and displaying charging costs on the Bulb app).
Landlords and estate agents: data such as your name and contact details may be provided to us by people moving in or out of a property you’re occupying, or a landlord or estate agent. We may use this information to contact you in relation to the continuation of the energy supply to your property.
Councils, postal services, and data brokers: information such as contact details, homemoving status and other details about your circumstances can be provided by councils, postal services and data brokers. We will always check that these organisations have your consent or are otherwise legally permitted to share this information.
Referrers: data such as your name and contact details may be provided to us by people referring you to Bulb as part of our Referral Programme. We may use this information to contact you in relation to becoming a Bulb energy member.
Green Deal database: if you have a Green Deal Plan, we will collect information from the Green Deal database to find out who your Green Deal Provider is, your Green Deal ID number, your Green Deal Plan start and end date and your daily charge amount.
Tully and OpenWrks: we have partnered with these companies to enable us to provide assistance to eligible members experiencing problems making their monthly payments to Bulb. This is explained in more detail at section 8.9 below. Through these companies, we receive recommendations for monthly payments you can afford but we don’t see your bank details or other financial information.
8. How we use this information
It’s important that you understand what we’ll do with the data that we hold about you, as well as the lawful reasons we are allowed to do this.
We may sometimes combine information that we collect from you with information we obtain about you from third parties and affiliates and information derived from any other subscription, product, or service we may provide.
We use the information we hold about you for the following purposes:
8.1 Performing our energy contract with you
We need to process information to verify you are a Bulb member and supply your energy (and any other goods or services you’ve asked for) under our energy contract. This may also involve sharing information with third parties as explained in section 9 below. For example, we may use your information (such as your contact information) to organise your switch to Bulb, to take monthly payments and organise meter repair jobs. If you have a Green Deal Plan, we need to process information about you (consumption data, contact information) and your plan so that we can collect payments from you so we can perform your contract with your Green Deal Provider.
8.2 Performing our carbon offsetting contract with you
We need to process information so we can offset your carbon footprint and provide the services you’ve asked for under our carbon offsetting contract. For example, we may use your information (such as your contact information) to let you know we received your monthly payment(s) to offset your carbon footprint, tell you about the carbon reduction projects your money is supporting, and remind you when it’s been a year since you signed up.
8.3 If we provide you with energy, fulfilling our legal and regulatory energy obligations
Many of the ways we manage your energy are based on requirements set out in our Licence and by Ofgem directions and Codes, such as how we set out your annual statement and how we deal with disputes.
8.4 If we need to share information with professional advisors
We will sometimes need to share information with our external professional advisors in the context of running our business. These professional advisors may include accountants, lawyers, financial advisors and PR and communications firms.
8.5 Fulfilling our general legal obligations
We may also need to comply with court orders, and disclose information to law enforcement agencies where we are obliged to do so.
8.6 If we provide you with energy, adding you to our Priority Services Register with your consent
If you have let us know that you (or a member of your household) need extra care or are in a vulnerable situation, we will ask for your explicit consent before we add your details to our Priority Service Register. This helps us take steps to ensure your safety.
8.7 If we provide you with energy, taking your smart meter readings with your consent
If you have a smart meter, we’ll normally collect readings from your smart meter once a day. You can decide whether we take a reading for the entire 24-hour period or for each half-hour period. We won’t take more than one reading a day unless you have given us your consent. If you’d prefer us to only take one reading a month, you can choose how often your smart meter takes readings in your Bulb account. However, if you are on a tariff that requires half-hourly readings, then you consent to these readings being taken and understand that if you withdraw your consent, you may not be able to benefit from this tariff.
8.8 If we provide you with energy, analysing your smart meter readings to offer you new products and services with your consent
If you have a smart meter, we could use your smart meter readings to understand how you use your energy. For example, we could learn how to buy energy for lower prices and be able to build and offer you new products and services. We will only use your smart meter readings to do this if you have given us your consent. You can email us at email@example.com at any time to withdraw this consent.
8.9 Where you need help paying for your energy and choose to use the Tully service to adjust your monthly payments
If you are experiencing financial difficulty, we have partnered with Tully to help you manage your monthly energy payments. Tully partners with a financial technology company called OpenWrks to provide their service.
Tully and OpenWrks are separate data controllers, independent of Bulb. If you choose to use Tully’s service, you enter into a contract with both companies directly – you’ll be notified of this at the time. Their privacy policies are available to read at the links below – you should make sure you are familiar with them:
When you sign up to use Tully, you will be asked to give your consent for Tully and OpenWrks to access your bank account data so they can see your transaction history and financial information from the previous 18 months. This consent will remain in place for the next 90 days.
Tully and OpenWrks will never make payments to Bulb on your behalf.
Tully will make a recommendation to Bulb every 30 days over a 90 day period about the amount you can afford to pay towards your energy bills – they will do this by analysing your transaction history and financial information. With your consent, this may result in your energy payments automatically increasing or decreasing. Bulb will always provide 10 working days’ notice of any payment or direct debit changes which occur as a result of Tully’s recommendation. A ‘working day’ is Monday to Friday, excluding English public holidays.
If you disagree with Tully’s assessment of your new financial situation you can contact them: firstname.lastname@example.org.
If you disagree with the planned payment changes Bulb sends you by email, you can reply to the email within 7 calendar days of the email being sent to discuss it with us and we will review the automated decision.
If you want Bulb to stop making automated decisions based on Tully’s recommendations, you can withdraw your consent by contacting your bank.
You can withdraw your consent for Tully and OpenWrks to access your bank transaction history and financial information at any time, by contacting your bank. This will end any adjustments that have been made to your usual payment amount and will mean that your monthly payments will switch back to your original payment amount, based on your energy usage and any debit repayment. You will be given 10 working days’ notice of this payment change by email. If you disagree with the planned payment changes Bulb sends you by email, you can reply to the email within 7 calendar days of the email being sent to discuss it with us.
If your monthly payment amount does increase as a result of your use of Tully, it will be based upon what you can afford according to the budget created by Tully. If the budget created by Tully results in Bulb increasing your energy payments, we will always ensure that any debt repayment takes place over 12 months or more.
After 90 days, if your financial situation has not improved and you are still in need of payment relief, Tully and OpenWrks will ask again for consent to access your bank account and financial information for a further 90 days. Tully will continue to make recommendations to Bulb every 30 days during this extended period.
Bulb will continue to use the recommendation from Tully to decrease or increase your payment automatically, after giving you 10 working days’ notice by email. As before, you can withdraw your consent for Tully and OpenWrks to access your financial information at any point by contacting your bank.
How Bulb uses the information it receives from Tully to make automatic decisions about your monthly payments
Bulb will make an automated decision about what amount you should be paying towards your energy bill based on the recommendation it receives from Tully. We’ve set out an example below so you can understand the logic behind this automated decision making. If you need further information please contact email@example.com.
1. A member’s monthly payment amount with Bulb is £50 a month, which is based on the member’s energy usage. However, they also have a £120 worth of debt on their Bulb account from previous energy usage which they need to pay off – Bulb recommends that they pay this off at £10 a month over the course of one year. Taking these two monthly amounts together, the member’s suggested payment amount is £60 a month (£50 for their energy usage and £10 for their monthly debt repayment).
The member gives consent to Tully, who works with Openwrks to understand the member’s income and expenditure from the financial information and transaction history of the member’s bank account. Tully will create a budget, including the amount that is affordable for the member to pay Bulb right now. In this case Tully’s budget shows that the member cannot afford to pay the £10 a month towards their outstanding debt. Bulb automatically lowers the member’s total monthly payment to £50 a month for 90 days. Bulb will notify the member of this change 10 working days’ in advance via email. This means that the payment for the outstanding debt will be spread out for a further period of time. For another 60 days, Tully will continue to provide Bulb with updates each month on how much you can afford to pay towards your energy.
2. After 60 days, Tully’s budget shows that the members’ income has increased and they can now afford to start paying off the outstanding debt. Bulb contacts the member 10 working days’ in advance of the amount being taken from the member’s account, letting them know that their payments will increase back to £60 to start paying their outstanding debt off too.
Every 30 days Tully will update Bulb about whether this budget is still accurate. Bulb will never ask you to pay more than you can afford based on the recommended budget created by Tully.
8.10 For our legitimate business interests
This means that using your information is necessary for us to build our business and provide our services to you. We consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests. Our legitimate interests include:
Maintaining and improving our goods and services: for example, we may use your information that we obtain through your emails and calls to train our team. We may also use your information to ensure that our services are working as intended – for example, understanding which parts of the website are easiest to use. We may also contact you for suggestions on how we can improve the way we provide our services to you.
Providing personalised services, including suggested payment amounts: for example, if we provide you with energy, we may use information such as your account balance and expected annual energy use to make an automatic adjustment to your payment amount.
If you use our Carbon Calculator, we may use your information such as the amount of carbon emissions you offset last year as an indicator of how big your carbon footprint will be the following year. We may then use that information to suggest you offset a similar amount of carbon emissions. We may also provide you with information so you can compare your carbon footprint with other people in your area.
Providing personalised advertising: we may let advertising platforms like Facebook and Google know that you are a member of Bulb or that you use our Carbon Calculator by sharing your contact details with them. This means we can stop asking you to join Bulb once you’re with us, or stop asking you to try our Carbon Calculator, and instead share information with you that we think you might be interested in. You can email us at firstname.lastname@example.org at any time to opt out of this.
Communicating with you about our goods and services: we may contact you about Bulb news, product updates and new products that we think you might be interested in. We may also contact you to provide you with offers, competitions, marketing materials and other promotional materials, both online and through other marketing channels, such as third party social networks, like Facebook. We do not contact our members with marketing messages through SMS or direct messaging via social media. You can email us at email@example.com at any time to opt out of this.
Measuring our performance and developing new services: for example, we use data for measurement to understand how our services are used. We also use aggregated data to understand our members and their energy usage or the size of their carbon footprints better. This helps us develop offerings such as our Annual Impact Report.
Helping to prevent and detect fraud or debt: we also need to be able to detect and prevent fraud and recover unpaid energy bills.
If you have questions about the lawful basis on which we collect and use your information, you can email our Data Protection Officer at firstname.lastname@example.org.
9. Sharing your information
9.1 When we share your information
We share information with companies that are members of the same group of companies as Bulb and with third parties. These companies process the personal information we hold about you on our behalf, for the reasons set out in this Policy or as otherwise required by law.
We make sure that these third parties won’t use your personal data for their own purposes (unless we have specifically stated otherwise in this policy ) and we only permit them to use it in accordance with our instructions and the law. This includes the following types of organisations:
Energy industry partners (if we provide you with energy or pay you for energy you export): including your old supplier, other suppliers, network operators and energy market administrators. This includes those organisations that maintain the national energy databases.
Payment providers: we work with payment providers to process your payments. If we provide you with energy, we use GoCardless to process your direct debit payments, Stripe to process your debit card payments and Transferwise to process other payments to you (such as under the Feed-in Tariff, the Smart Export Guarantee or for referrals if you have a prepayment meter). If you use the Carbon Calculator to offset your carbon footprint, we use Stripe to process your credit or debit payments. You can find more information on how these providers process your personal data and your data protection rights by looking at their privacy policies at the links above.
Marketing agencies, search engines and social media networks: to advertise Bulb and to gather feedback on Bulb such as through customer surveys.
People you have authorised us to share data with (if we provide you with energy): such as family members, energy brokers, solicitors and debt management companies, so we can fulfil your requirements.
Market regulators (if we provide you with energy): such as Ofgem and consumer protection organisations such as the Energy Ombudsman, where we are obliged to do so under regulations.
Price comparison sites and other affiliates (if we provide you with energy): if you have signed up to Bulb using a price comparison site or via an affiliate link. We then provide the affiliate with your personal data such as your email address, only to the extent that we can fulfil a contract you have requested.
Credit reference agencies (such as Experian, Equifax and TransUnion) (if we provide you with energy): When you open an account with us we may use a credit reference agency to check your credit score. This may leave a footprint on your credit record which other suppliers and lenders will be able to see. Once you are a Bulb member, we may share your payment performance history with credit reference agencies from time to time. This includes sharing data on paid and missed or failed payments. We may also tell credit reference agencies how you’re managing your account and whether you owe us money, which may impact your ability to obtain credit in the future. These agencies can help us trace you if you have moved and we owe you money or you owe us money. More information is set out in Experian’s Credit Reference Agency Information Notice, Equifax’s Information Notice and TransUnion’s Credit Reference Agency Information Notice. We also use credit reference agencies to support us in providing additional financial analytic data to enable us to make management forecasting and business decisions.
People you are referring to Bulb so we can provide them with energy: if you refer a new energy member to us, we may share your name and aggregated data about your energy use with the referred person.
Post Office: if you are eligible for a Warm Home Discount and Affordable Warmth Measures and you are a prepayment member, we may share your name and postal address with the Post Office so that the Post Office can verify your identity when you collect your credit.
Green Deal providers: if you have a Green Deal plan, we may share your information with your Green Deal provider so that we can pay them for the energy efficiency measures you have purchased or where necessary, the UK government to show our compliance with the scheme.
9.2 When you share your own information
Sometimes you may share your information publicly, such as by posting on our Community page or on social media sites. Remember, when you share information publicly it may become accessible through search engines.
9.3 Sending your data outside the European Economic Area
Sometimes our agents and service providers are based outside the European Economic Area, so when working with them, we may pass your information outside of the European Economic Area to countries that do not have the same data protection standards as the UK.
10. You’re in control
10.1 Your rights
If we collect or handle your personal data, you have rights as an individual which you can exercise in relation to the information we hold about you:
To correct or update your personal information, you can log into your Bulb account .
To delete your personal information, you can email us at email@example.com. We will delete any information that we no longer need to hold, but we won’t always be required to do this. For example, we may need to hold your information to continue to provide your energy under our contract. If this is the case, we’ll explain why.
To ask us to restrict processing of your personal information or transfer your personal information to a different organisation, you can email us at firstname.lastname@example.org.
To confirm if we are using your personal information or get access to all your personal information that we hold, in an easy to understand, portable and secure format, you can email us at email@example.com with the subject line “Subject Access Request”.
To object to the processing of your personal information, you can email us at firstname.lastname@example.org.
To withdraw consent to process your data, you can email us at email@example.com at any time.
To opt-out of marketing communications you can email us at firstname.lastname@example.org.
To withdraw your consent to the automated decisions related to the financial assistance programme explained in section 8.9 or to receive information about the basis upon which such decisions have been made you can email us at email@example.com.
Once we receive a request from you, we will respond within at most 1 month, but usually a lot quicker. Before actioning these requests, we will need to positively identify you. In line with our Member Service wait time policy, we aim to send responses to all emails within an hour.
If you’re unhappy with how we’ve handled or processed your personal information – or you want further information about your rights – you have the right to contact the Information Commissioner’s Office, the supervisory body that regulates handling of personal information in the UK.
10.2 Keeping your information secure
Whilst we cannot ensure or guarantee that unauthorised access to or unauthorised alteration, disclosure or loss of information will never occur, we work hard to prevent it. In particular:
We use encryption to keep your data private while in transit.
Your account information is protected for your privacy and security. Either this is through a password you have chosen or you can log-in to your account directly with your email address. Bulb and our agents will never ask for your password.
To help keep your account and your personal information secure you should not disclose your password details to anyone. You should also make sure your Bulb account password is different from your email address password. We recommend you change your passwords from time to time.
We review our practices for collecting, processing and storing personal information, including physical security measures, to guard against unauthorised access to systems and backups to prevent the loss of information. We will continue to enhance our security procedures as new technology becomes available.
We restrict access to personal information wherever possible to people who need to know that information to process it and who are subject to contractual confidentiality requirements.
10.3 Retaining and holding your information
We keep the personal information we collect for no longer than is necessary for the purposes for which we collected it.
The length of time depends on the purposes for which we use it, or otherwise to meet our legal obligations.
We will delete any information as soon as we no longer have a valid reason to hold it. If this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
11 Contact us
12. About this Policy
12.1 When this Policy applies:
For the purposes of this Policy, “we”, “us”, “our” and “Bulb” means Bulb Energy Ltd and other companies in the same group. Unless otherwise stated, Bulb is the Data Controller for your personal data.
This Policy applies to how we use your information in relation to our products and services generally.
This Policy doesn’t apply to other companies’ sites that you get to through our website, social media pages or where you link to our affiliates and partners via our Bulb store. So make sure you’ve read their policy before putting your personal information on their site.
12.2 Changes to this Policy:
We may change this Policy at any time. If we make any changes, we’ll post them on this page. If they’re substantive changes, we’ll also have a more prominent notice letting you know. You can also email or write to us for a physical copy.
Last updated: The Policy was last updated on 17 August 2021.