Last Updated: 01/10/2020

This Privacy Policy describes how Impactware Technology Solutions Pvt. Ltd. and its affiliates (collectively, goEgo, goEgoNetwork, Impactware or ‘we’ or ‘us’ or ‘our’) collect, use and disclose information about you and what choices you have with respect to your information.

Your privacy is really important to us. So whether you’re new to Impactware or a long-time user, please take the time to get to know our practices. We have made some updates to the format of this Privacy Policy to help you more easily find information. Our privacy practices have remained the same. We have kept this simple to make it easy to understand, but if you are not familiar with any terms in this Privacy Policy, please reach out to us. This Privacy Policy applies to all personal data collected and used by goEgo Network. The data in question is customer data as provided by you but also for example data on visits to our website, goConnect platform, goME mobile app, sign-ups for our newsletters and participation in campaigns or promotions or data regarding charging sessions and charge points.

Introduction – what is personal data?

"Personal data" is all types of information that can be related directly or indirectly to a living natural person. Impactware Technology Solutions Pvt. Ltd. (Impactware) is the personal data controller of the data that you provide or that we retrieved from another source. Impactware always processes personal data with the greatest respect for personal integrity. The guidelines applied by Impactware, methods for managing and storing information and your rights are described below. The guidelines never restrict the rights that apply according to the Data Protection Regulation or any other legally binding provision. Contact details for the personal data controller and data protection officer can be found under Contacts.

Collection of personal data

We collect personal data using the following methods:

1. You personally enter your data, such as when becoming a customer and other situations. For example, via our website, mobile apps, on physical forms, in contacts with customer services or sales, by e-mail, letter, contact forms and through login services etc.
2. You personally provide your data to a supplier of price comparison services.
3. Information is created based on your purchases, how you use our services.

Additionally, following data from third parties:

1. Contact details and demographic data from public sources.
2. Data regarding credit ratings from banks or credit institutions.
3. Data from other players in the energy industry with the purpose of enabling electricity supplier changes and moves.
4. Data from our partners.

Personal data categories

The following categories of personal data are normally collected:

1. Customer information, that is, the requisite information for becoming a customer. For example, name, address, flat number, property designation, phone number, e-mail address, choice of communications channel.
2. Purchase information, that is, purchased products and services, credit rating, payment history, customer number and password.
3. Technical information, that is, your electricity and/or heating consumption, electricity and grid supplier, plant number, issues and interruption history and type of connection.
4. Service information, that is, specific ticket correspondence, information on purchases and any complaints or claims. Customer survey results and feedback on our products and services. Where applicable, data obtained through competitions.
5. Demographic information (from public records), that is, age, gender, housing area, household demographics, etc.
6. Website traffic information of login services, that is, purchase and user generated data, password, technical data of the device used, interaction data (duration of visit, response times, access and log out methods, etc.)
7. Recorded information, recording of power of attorney for change of electricity supplier or move, recording of acceptance of purchase over the phone and recording of conversations for quality assurance and for training of our staff. Special categories of personal data are only processed in exceptional cases. To process personal data in these cases, we must obtain your consent. There are also occasions in which we are legally obligated to collect and process these types of sensitive personal data.

Purpose and legal ground for processing

We only collect personal data for purposes that are supported in the current regulation. Most commonly, data are collected for processing to support the legal ground for fulfilling the agreement.Examples of purposes:

1. To enter into an agreement with us/become a customer
2. To receive a quote for a promotional offer
3. To purchase a product/service
4. To manage customer service queries.With our legitimate interest as grounds, we process data for several purposes, such as:
5. For marketing and profiling, that is, to communicate relevant offers to our clients
6. For sales of our own and partner offers
7. To send newsletters
8. To develop and improve our products and services
9. For statistics and analyses.

Other purposes for processing personal data may have their legal ground in legal requirements, i.e. when we must fulfill a legal obligation. Examples of such purposes are processing personal data for invoicing in accordance with accounting legislation or when we inform of the changed agreement terms.You can also give consent for processing in certain cases when none of the above applies. The provision of consent is an affirmative action on your part and can be withdrawn. We will then discontinue processing your personal data for that purpose.We do not process personal data for purposes that are inconsistent with the original purpose. More information on the purpose for which personal data are used can also be provided when the data is collected, for example, in connection with e-mail forms or in agreement terms.

Data collection information

When we collect personal data, the data subject providing the data will receive the following information:

1. the purpose for and legal grounds on which the personal data is collected,
2. contact details for the personal data controller and data protection officer,
3. your rights,
4. how long the data will be stored.

Should you find this information to be unclear or incomplete, we ask that you contact Impactware to obtain complete information.

Transfer of personal data

Because Impactware Technology Solutions shares some functions, your personal data may be passed on to other companies in the Group. These companies may also process your data with the purpose of providing offers and marketing of products and services that may interest you.Under certain circumstances, we may also pass on personal data to personal data processors, partners or another third party.

The parties that may process collected personal data are:

1. IT suppliers
2. Customer support suppliers
3. Sales partners/other partners
4. Installers (e.g. of solar panels or heat pumps)
5. Technical service contractors
6. Telemarketing companies
7. Printing and digital communications partners

Personal data retrieved from other parties

We may purchase personal data from other sources, primarily to discover target groups for our offers. This processing is based on the individual having requested an offer or entered into an agreement with us through the source or, that the individual has given the source his/her consent to transfer data to us. Partners may send information about you that you have provided to the partner, thereby giving consent to transferring the information to Impactware as a result of your interest in becoming our customer or to obtain an offer from us.

Access to personal data

Only those who need access to personal data to perform the agreed service will be given authorization to access and process the data. Several of our subcontractors process personal data to different degrees, but all have the same requirements for processing as specified in Impactware Technology Solution’s internal requirements.

Retention

We do not keep personal data for longer than necessary and we follow the legal requirement of the country.

Security

We take special physical, technical and organisational measures to protect the personal data that are processed to ensure that the data are not lost, destroyed, manipulated or subjected to unauthorized access. The measures aim to achieve a suitable security level with respect to available technology. Changes to personal data are continuously registered to ensure trace-ability of all changes made to the information.

Your rights

Right of access

Each individual is entitled to receive information on the extent to which his/her personal data is processed by Impactware Technology Solutions. If such personal data is kept by Impactware, the person concerned may request information on the categories of personal data that are processed, from where they were obtained, for what purpose they are processed, what the legal grounds are for processing and with whom data has been shared. Impactware will send a transcript to the address registered with Impactware within a few months from receiving the request.

Right to rectification

Each individual has the right to request rectification of their own customer information if it is incorrect or processed contrary to applicable law.

Right to erasure

Impactware deletes personal data when legal grounds for keeping the data no longer exist. Our customers are entitled to immediate deletion of their personal data if any of the following apply:

1. Processing is based only on your consent, and you have revoked that.
2. The data are no longer necessary for the purposes they were processed.
3. The processing is for the purpose of direct marketing and you object to your data being used for this purpose.
4. The information has not been processed in accordance with the regulations.
5. You object to processing after your interest is deemed to override the legitimate interest of the controller.
6. Deletion is required to meet a legal obligation.

Cookies

Impactware Technology Solutions or goEgo Network uses cookies to recognize you on a subsequent visit to the website. A cookie is a small text file a website requests to save on your device (computer, mobile…). You decide how your device handles cookies through the settings in your web browser. Check your web browser's help pages for more information about how you block or delete cookies. We are using first party and third party cookies for various purposes. Some of the cookies placed on your device are erased when you leave our site (session cookies) while others can remain on your device for up to two years so that the website recognizes you if you return (persistent cookies).

We don't collect information about visitors' IP addresses and therefore the information collected is never linked to your identity. We use cookies to:- Facilitate the use of our site and load pages quickly on your device (first-party session cookie). To provide personal contact in connection with the signature of a contract. For example, when you complete a form and are asked to sign an electricity contract, you will get asked if you want to be called back or get help (Third Party session cookie) We also use analysis tools such as SiteCatalyst (first party session and persistent cookies) and Google Analytics (third party session and persistent cookies) to collect statistics about how visitors move around our website. For example:

1. If the visitor has been to our website before.
2. Where the visitor has clicked on our website.
3. How long the visit took.
4. Which browser was used.

We use external partners to streamline and monitor our sales campaigns and marketing (third party permanent cookie). Everyone who visits a website with cookies will get access to information on the website with the desired outcome of using the cookies. Visitors can also give their consent to use cookies.

Information about Google Analytics and Google AdWords Google Analytics

This function allows us to view information about the use of our websites, including the viewing of pages, the source of the visit and the time spent on our websites. The information is anonymised and presented in statistical form, so that it cannot be traced back to the user. With Google Analytics we can see what content is popular on our websites, so that we are better able to provide users with useful information.

Google AdWords (incl. DoubleClick)

This function is used to advertise on third-party websites (including Google) aimed at visitors to our websites. This helps us to offer our products to visitors to our websites on a more focused basis. Blocking cookies Cookies can of course also be blocked. Most Internet browsers can be set so that cookies are not accepted or so that you are notified when you receive a cookie. The way in which you can do this depends on the browser you use. You must remember that certain parts of the website may not work or may not work properly if you block cookies and in certain cases access to the website is impossible without them.