1. Important notice
    This Privacy Policy describes how we obtain and use your personal data, why we are allowed
    to do so by the law, who has access to your personal data and what your rights are. Please
    review it carefully.
    We are Turbine Marketing Limited and are registered with Companies House at Fitzwilliam
    House, Middle Bank, Doncaster, South Yorkshire, England, DN4 5NG. Company Number
    08530306.
    Our contact details are:
    Fitzwilliam House, Middlebank, Doncaster, DN4 5NG
    Phone: 01302898508
    Email: [email protected]
    ICO Registration ZA028824
    In the event that the Site contains a separate Privacy Statement linked to via the Site
    homepage, in the case of conflict between that Privacy Statement and this Privacy Policy,
    the Privacy Statement shall prevail over this Privacy Policy
    We take your privacy seriously and use your personal data as further explained in this Privacy
    Policy. We are the “controller” of the personal data you provide to us.
    You have the right to object to us processing your personal data for our legitimate business
    interests or for direct marketing purposes (including any related profiling). For more
    information about your rights and how you can exercise them, please see the section Your
    rights.
  2. Personal Data we may collect and why
    Personal data is any information which identifies you personally whether directly (for
    example, your name) or indirectly (for example, information about your use of our products
    and services).
    We may collect the following data about you:
    • Contact details: your name, email address, and telephone number so that we can
    contact you in response to an enquiry you make via our Site or in relation to the
    products and services that we have from time to time agreed to provide to you;
    • Correspondence: we collect any additional personal data you may provide to us
    from time to time if you contact us by email, letter or telephone, through our Site, by
    submitting a comment on our Site, or by any other means;
    • Survey responses: information from surveys that we use for research purposes, if you
    choose to respond to them;
    • Transaction details: we or our third party providers will collect information relating to
    transactions you carry out through our Site and for the purposes of fulfilling your
    orders;
    • Details of visits to the Sites: details of your visits to our Site, including, but not limited to,
    traffic data, location data, weblogs and other communication data, whether this is
    required for our own billing purposes or otherwise and the resources that you access.
  3. Cookies
    What are Cookies?
    We collect information about your use of our Site through cookies. Cookies are information
    that files stored on your computer, tablet or smartphone that help websites remember who
    you are and information about your visit. Cookies can help to display the information on our
    Site in a way that matches your interests. Most major websites use cookies.
    a. What cookies are used on this Site?
    The cookies we and our business partners use on our Site are broadly grouped into the
    following categories:
    • Essential – Some of the cookies on our Site are essential for us to be able to provide
    you with a service you have requested. An example of this could be a cookie used to
    enable you to log into your account on our Site or which allows communication
    between your browser and our Site. Our cookie preference cookie described in the
    section “How can I reject or opt out of receiving cookies?” is also an essential cookie.
    You may not be able to use our Site without these cookies.
    • Analytics – We use analytics cookies to helps us understand how users engage with
    our Site. An example is counting the number of different people coming to our Site or
    using a particular feature, rather than the total number of times the site or feature is
    used. Without this cookie, if you visited our Site once each week for three weeks we
    would count you as three separate users. We would find it difficult to analyse how
    well our Site was performing and improve it without these cookies.
    • User Cookies – We use cookies to improve your experience by remembering your
    preferences, so we know how you like to use our Site. Examples of this would be
    remembering you so that you are served with the same content or to remember you
    when you come back to our Site.
    • Social Sharing – We use third party cookies to allow you to share content directly on
    the social networking/sharing sites like Facebook, Twitter or Google+. Examples would
    be if you wanted to “like” or “tweet” about us or our products or services. Please see
    our “Third Party Cookies” section below for more details.
    • Interest-Based Advertising – You will have noticed that when you visit websites you will
    be shown adverts for products and services you may wish to buy. The money made
    by website owners for showing third party adverts on their websites often pays for the
    cost of running the website and therefore usually allows you to use the website
    without having to pay a registration or usage fee. To try and ensure that the adverts
    you see are relevant to you third party cookies may be used to collect information
    about the types of things that interest you, for example websites you visit and the
    geography that you are based in. Having these cookies does not increase the
    number of adverts you will be shown, but simply makes the adverts you see more
    relevant. Please see our “Third Party Cookies” section below for more details.
    b. How can I reject or opt out of receiving cookies?
    You may refuse to accept cookies by activating the setting on your browser which allows
    you to refuse the setting of cookies. However, if you select this setting, you may be unable to
    access certain parts of our Site. Unless you have adjusted your browser setting so that it will
    refuse cookies, our system will issue cookies when you use our Site. The “Help” menu of the
    toolbar on most browsers will tell you how to prevent your browser from accepting new
    cookies, how to have the browser notify you when you receive a new cookie, or how to
    disable cookies altogether. For more information about cookies and how to stop cookies
    being installed or how to delete existing cookies from your hard drive visit the following
    website: http://www.allaboutcookies.org.
    c. Third party cookies
    Some of the cookies described in the “What Cookies are used on our Site” section above are
    stored on your machine by third parties when you use our Site. Third parties may also read
    cookies on your browser to collect information or to serve content or advertisements to you.
    We have no control over these cookies or how the third parties use them. They are used to
    allow that third party to provide a service to us, for example analytics. For more information
    on these cookies and how to disable them, please see:
    • Internet Advertising Bureau website at http://www.youronlinechoices.com/ where
    you will be able to opt-out of receiving Interest-Based Advertising cookies from some
    of the third parties listed below; and/or
    • If you want to know more about how cookies work and how to manage or delete
    them, visit the World Wide Web Consortium’s website.
  4. How we use your personal data
    We use your personal data for the following purposes:
    To provide you with the products and services you have requested
    We use your personal data to accept you as a new or returning customer to provide you
    with the products and services you have requested in accordance with the Trading Terms or
    Terms of Trading.
    To send you service communications, including in relation to changes to our Trading Terms or
    Terms of Trading
    We use the contact details you have provided to us so that we can communicate with you
    about the products and services that we provide, including to let you know about major
    changes to those products and services or to the Trading Terms or Terms of Trading between
    us or to any related information.
    Direct marketing (including by third parties)
    If you have provided your consent or we otherwise have the right to do so, we may use your
    contact details to send you direct marketing and keep you informed of promotional offers by
    email, SMS, post or telephone relating to our products and services.
    You can unsubscribe from our direct marketing at any time by clicking the “Unsubscribe” link
    in any of our emails or by contacting us.
    Our trusted business partners include HIES who will require use your name, email address,
    postal address and telephone number to register your products with them. We will only share
    your personal data with our partners where you have provided us with your consent to do so.
    HIES is a consumer protection organisation covering the installation of renewable energy and
    home energy efficiency products.
    You can unsubscribe at any time by clicking the “Unsubscribe” link in any of their emails or by
    contacting us.
    To track your usage of our website, communications, products and services
    We use cookies and similar technologies to track your activity on our Site so that we can
    provide important features and functionality on our Site, monitor its usage, and provide you
    with a more personalised experienced.
    To provide and improve customer support
    We use your personal data to be able to provide and improve the customer support we
    provide to you (for example, where you have questions about our products and services).
    To maintain our records and improve data accuracy
    Like any business, we process personal data in the course of maintaining and administering
    our internal records. This includes processing your personal data to ensure that the
    information we hold about you is kept up to date and accurate.
    To respond to enquiries, complaints and disputes
    We use the personal data we hold about you to help us respond to any enquiries or
    complaints you have made, or deal with any dispute which may arise in the course of us
    providing our products and services to you, in the most effective manner.
    To investigate, detect and prevent fraud and comply with our legal obligations
    In certain circumstances, we use your personal data only to the extent required in order to
    enable us to comply with our legal obligations, including for fraud detection, investigation
    and prevention purposes. This may require us to provide your personal data to law
    enforcement agencies if they request it.
  5. Legal grounds for processing
    Data protection law requires us to only process your personal data if we satisfy one or more
    legal grounds. These are set out in data protection law and we rely on a number of different
    grounds for the processing we carry out. These are as follows:
    Consent
    In certain circumstances, we process your personal data after obtaining your consent to do
    so for the purposes of:
    • sending you marketing communications about our products and services;
    • sharing your name, email address, postal address and telephone number with our
    trusted business partners so that they may market to you about their own similar
    products and services;
    • conducting marketing research;
    • obtaining your credit score so that we can establish the best possible payment terms
    we are able to offer to you.
    Necessary for the performance of a contract and to comply with our legal obligations
    It is necessary for us to process your basic contact details, payment details and information
    about the business you represent for the performance of the Trading Terms or Terms of
    Trading between us. In particular, we rely on this legal ground to:
    • provide you with the products and services;
    • communicate with you about the products and services that we provide to you,
    including to let you know about major changes to those products and services or to
    the Trading Terms or Terms of Trading between us or to any related information;
    • provide and improve customer support; and
    • notify you about changes to our service
    If you choose not to give some or all of the aforementioned information to us, this may affect
    our ability to provide our products and services to you.
    In certain circumstances, we also use your personal data only to the extent required in order
    to enable us to comply with our legal obligations, including to detect, investigate and
    prevent fraud.
    Necessary for the purposes of our legitimate business interests or those of a third party
    It is sometimes necessary to collect and use your personal data for the purposes of our
    legitimate interests as a business, which are to:
    • provide you with products and services that are as useful and beneficial as possible,
    including by personalising our contact with you and making sure we tell you about all
    the offers that are relevant to you;
    • better understand our customer base so that we can improve our products and
    services and marketing activities (which could also benefit you);
    • comply with our contractual obligations to third parties;
    • develop and improve our Site to enhance the customer experience;
    • train our staff so that we can provide you with a better customer service;
    • respond to any enquiries or complaints you have made, or deal with any dispute
    which may arise in the course of us providing our products and services to you; and
    • to ensure that content from our Site is presented in the most effective manner for you
    and for your computer;
    • ensure effective operational management and internal administration of our
    business, document retention, compliance with regulatory guidance and exercise or
    defence of legal claims.
    Where we think there is a risk that one of your interests or fundamental rights and freedoms
    may be affected we will not process your personal data unless there is another legal ground
    for us to do so (either that we have obtained your consent to the processing or it is necessary
    for us to perform our contract with you or to comply with our legal obligations).
  6. Who we share your personal data with
    We may provide your personal data to our suppliers and service providers, who provide
    certain product services for us and act as “processors” of your personal data on our
    behalf. In addition, we may disclose your personal data if we are under a duty to disclose or
    share your personal data in order to comply with any legal obligation, or in order to protect
    the rights, property, or safety, of our business, our customers or others. This includes, in specific
    cases, exchanging information with other organisations for the purposes of fraud protection.
    In some cases, the personal data we collect from you will never, for the purposes set out
    above, be transferred outside the European Economic Area (EEA) and such destinations
    may not have laws which protect your personal data to the same extent as in the EEA. We
    are required by data protection law to ensure that where we or our “processors” transfer
    your personal data outside of the EEA, it is treated securely and is protected against
    unauthorised access, loss or destruction, unlawful processing and any processing which is
    inconsistent with the purposes set out in this Privacy Policy.
  7. How long we keep your personal data for
    We retain your personal data for no longer than is necessary for the purposes(s) for which it
    was provided. What this means in practice will vary between different types of data. When
    determining the relevant retention periods, we take into account factors including:
    • legal obligation(s) under applicable law to retain data for a certain period of time;
    • statute of limitations under applicable law;
    • potential or actual disputes; and
    • guidelines issued by relevant data protection authorities.
    • the products you have bought from us and their warranties
    Otherwise, we securely erase your personal data from our systems when it is no longer
    needed.
  8. Your data protection rights
    Under data protection law, you have rights including:
    Your right of access – You have the right to ask us for copies of your personal information.
    Your right to rectification – You have the right to ask us to rectify information you think is
    inaccurate. You also have the right to ask us to complete information you think is incomplete.
    Your right to erasure – You have the right to ask us to erase your personal information in
    certain circumstances.
    Your right to restriction of processing – You have the right to ask us to restrict the processing of
    your information in certain circumstances.
    Your right to object to processing – You have the the right to object to the processing of your
    personal data in certain circumstances.
    Your right to data portability – You have the right to ask that we transfer the information you
    gave us to another organisation, or to you, in certain circumstances.
    You are not required to pay any charge for exercising your rights. If you make a request, we
    have one month to respond to you.
    Please contact us at if you wish to make a request:
    Fitzwilliam House, Middlebank, Doncaster, DN4 5NG
    Phone: 01302898508
    Email: [email protected]
  9. How to contact the ICO
    If you would like to exercise your data protection rights or if you are unhappy with how we
    have handled your personal data, please feel free to contact the ICO by using the details
    set out on our Site.
    If you’re not satisfied with our response to any enquiries or complaint or believe our
    processing of your personal data does not comply with data protection law, you can make
    a complaint to the Information Commissioner’s Office (ICO) by:
    • writing to: Information Commissioner’s Officer, Wycliffe House, Water Lane, Wilmslow,
    Cheshire, SK9 5AF;
    • calling: 0303 123 1113; or
    • submitting a message through the ICO’s website at: ico.org.uk
  10. Links to other websites
    Our website may contain hyperlinks to websites owned and operated by third parties. This
    Privacy Policy does not apply to those other websites. We encourage you to read the
    privacy statements on the other websites you visit, as they will govern the use of any personal
    data you provide when visiting those websites. We do not accept any responsibility or liability
    for the privacy practices of such third-party websites and your use of such websites is at your
    own risk.
  11. Changes to this Privacy Policy
    Updated – March 2023