Privacy Policy

BT Commercial Limited (“we”, “us”) is committed to protecting and respecting your privacy. We are a data controller under the applicable data protection law, which includes the Data Protection Act CAP. 440 and the General Data Protection Regulation (Regulation (EU) 2016/679) as appropriate. This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide us, will be processed by us.

Prospective and Existing Customers

Information we collect about you and how we use such information

In acquiring products and/or services from us, or through a reseller or agent authorised to sell our products/services, you provide us with your personal data, which may include your name, postal address, email address, contact telephone number and ID card number.

We collect this data in order for us to deliver, install and perform any other services as may be necessary to fulfil our contractual obligations in accordance with the Terms and Conditions of Sale. We also have a legitimate interest to retain this data in order to provide you with any after-sales service that you may require us to provide over and above the guarantee issued by us. 

You may also provide us with your personal data when making enquiries on our products and services, including when you request a quote through our website.

We will use your personal data to provide you with the information, products and services that you request from us. We may further use this information to keep you informed about our products, promotions and news by sending you email communications from time to time. We have a legitimate interest to do so where you have acquired a good/service from us; otherwise, we require your express consent as provided for in the Consent Section of this Policy.

We will not share your personal data with any third parties, except where we are entitled or obliged by law or in the following specific circumstances:

  1. Where we engage sub-contractors to perform delivery and installation of our products/services on our behalf. In this case, appropriate measures of data protection are in place in our sub-contracting arrangements to ensure an adequate level of protection.
  2. Where you give us your consent to register with a third party energy monitoring portal to monitor the performance of the product acquired from us, as provided for in the Consent Section of this Policy.

Where we need to collect personal data by law, or due to our contractual obligations with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter with you.

How long we keep your information for

Unless a longer period is required or permitted for legal and regulatory purposes, we keep your personal information according to the expected useful life of the product you acquired from us, to enable us to provide you with any after-sales assistance you may require in an efficient manner.

Where you have provided us your personal data when making enquiries, but you did not acquire any product or service from us, we will retain this data for a period not longer than 12 months. This will allow us to retrieve the quote or other information provided to you, should you request such information during this period.

Applicants for Vacancies

Information we collect about you and how we use such information

During the recruitment process, we ask for information about you to be able to assess your suitability for employment. We do not collect more information than we need to fulfil this purpose and will not retain it for longer than is necessary.

If you apply with us for a post, we may collect the following information on you:

  • name and contact details
  • your previous experiences and details of your previous jobs
  • education details
  • referees’ names and contact details
  • answers to questions made to you during the recruitment process relevant to the role you have applied for

You are not obliged to provide this information, but your application may be affected if you don’t. 

Where we use recruitment agencies, such information is also obtained from the agencies you would have applied with. We may contact your referees, using the details you provide in your application, directly to obtain references.

We might ask you to attend an interview and we may conduct an assessment on the basis of the information collected from your application and the interview. Information will be generated by you and by us and if so, this information is held by us for the recruitment exercise and perhaps after if you are selected.

If we make an offer of employment, we will ask you for additional information so that we can carry out pre-employment checks. Depending on the job requirements, you may be required to provide the following:

  • proof of your identity
  • proof of your qualifications
  • police conduct certificate
  • bank details, to process salary payments
  • emergency contact details, so we know who to contact in case you have an emergency at work
  • health information, to ensure you are fit to work and to cater for any special conditions

This additional information is necessary to finalise your employment and onboarding process. Further processing of your information would be required if we are to apply for a work permit.

Our recruitment team will have access to all of this information. All of the information you provide during the process will only be used for the purpose of progressing your application, or to fulfil legal or regulatory requirements if necessary.

We will not share any of the information you provide during the recruitment process with any third parties for marketing purposes or store any of your information outside of the European Economic Area. The information you provide will be held securely by us and/or our data processors whether the information is in electronic or physical format.

We will use the contact details you provide us to contact you to progress your application. We will use the other information you provide to assess your suitability for the role you have applied for.

How long we keep your information for

If you are unsuccessful following assessment for the position you have applied for, we normally keep the information about your application for a period of 12 months, in case you raise any questions about the process. We may ask if you would like us to contact you for any other vacancy that may arise during this period. If you say yes, we may contact you should any further suitable vacancies arise within that period. You may ask us to cancel this at any time.

If you are employed, we will keep your personal data in accordance with our Employee Handbook.

Consent and Opt-out

We require your specific consent to process your information for each of the following purposes:

1. Marketing

We would like to keep you informed about our products, promotions and news. Unless you have acquired a good/service from us, we require your explicit consent for us to send you marketing email communications. For this purpose, when you request a quote through our website, you are asked to opt whether you would like to be included in our mailing list.

2. Energy Monitoring Portals

We recommend that you register, or that we register on your behalf, to suitable energy monitoring portals that allow monitoring of the performance of the product which you acquired from us.

If you give us access to view and monitor the performance information in connection with your product, we will be able to alert you to any issues arising and help you resolve them as quickly as possible.

You can withdraw your consent for either (a) or (b) above at any time by contacting us on [email protected]. You may also opt out of receiving marketing email communications either by using the unsubscribe function on the information we send you or by unsubscribing from the mailing list through our website.

Your rights

Under data protection law, you have the following rights, in relation to the way we process your personal data, although these are not absolute and in some instances, we may be unable to accept your request, in which case we will respond to you to explain why.

  1. Right to access personal data held by us about you.
  2. Right to require us to rectify your data without undue delay, in so far as it is inaccurate or incomplete.
  3. Right to restrict our processing of your data where you dispute the data’s accuracy; or where you have the right to require us to erase the data but you prefer that we restrict our processing instead; or where you need us to hold the data even if we no longer require it as you need to establish, exercise or defend legal claims; or where you have objected to our use of your data and we need to verify whether we have overriding legitimate grounds to use it.
  4. Right to require us to erase personal data held by us about you. This right will apply where we no longer need to use the personal data to achieve the purpose we collected it for; or where you withdraw your consent in line with (e) below; or where you object to the way we process your data in line with (f) below.
  5. Right to withdraw your consent, where we are relying on it to use your personal data.
  6. Right to object to our processing of personal data held by us about you where the processing of such data is necessary for the purposes of our legitimate interests, unless we are able to demonstrate, on balance, legitimate grounds for continuing to process personal data which override your rights or which are for the establishment, exercise or defence of legal claims.
  7. Right to receive the personal data which you had provided to us in a structured, standard and machine-readable format, and to request us to transmit this data to another organisation.

You may contact us as detailed below to exercise any of these rights. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Security of your personal data

We use reasonable efforts to safeguard the integrity, availability and confidentiality of all personal data that we process relating to you. We have put in place technical, physical and managerial procedures so as to ensure that your personal data is protected from unauthorised access; improper use or disclosure; unauthorised modification; unlawful destruction or accidental loss. We regularly review and, where practicable, improve upon these security measures.

All our employees and data processors, who have access to and are associated with the processing of personal data, are further obliged to respect data confidentiality.

By its very nature however, the Internet is not a secure medium and data sent via this medium can potentially be subject to unauthorised acts by third parties. Although we take appropriate precautionary measures, we cannot guarantee the privacy or confidentiality of any information processed through this medium.

Moreover, data sent via the Internet may be transmitted across international borders even where sender and receiver of information are located in the same country.  Consequently, data relating to you may be transmitted via a country having a lower level of data protection.  We shall accept no responsibility or liability whatsoever for the security of your data while in transit through the Internet.

Third-party websites

Our website may contain links to third party websites operated by providers that are not associated with us. If you follow the 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 these websites.

Changes to our Privacy Policy

We will update this Privacy Policy from time to time in response to changing legal, regulatory or operational requirements. We will provide notice of any such changes in accordance with law.

How to contact us

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to: [email protected]

Furthermore, if you have any concerns regarding our processing of your personal data, you have the right to make a complaint to the Office of the Information & Data Protection Commissioner on [email protected]

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