Who We Are

New Measured Power Limited (t/a Pinergy) is a company limited by shares and registered in the Republic of Ireland.

Contact Us

You can contact us at our main business address: Suite 1, Beaver House, Beech Hill Office Park, Clonskeagh, Dublin 4.

Our Data Protection Officer can be contacted via dataprotection@pinergy.ie

Our Values

We believe that providing insights into how our customers use energy will help them to optimise their energy use, reduce waste and treat energy as a resource, not a commodity. We are also aware that data needs to be handled securely and transparently. We believe you should own your own data and should have the choice about who has access to your data or who you consent to view the data.

As part of our ethos of continuous improvement, this Data Protection Notice and any associated policies or procedures may be changed in the future. If we make changes, we will provide notice of any proposed changes at least thirty (30) days before they come into effect.

What We Do

The mission of Pinergy is to help our customers to understand their energy consumption and then reduce it in a sustainable way.

How Do We Obtain Your Personal Data?

When you use our products or services and apps, we collect information about you.  This information can be manually entered by you or be collected automatically from your smartphone and/or meter device. Other information may come from third parties, such as your landlord, property manager or developer.

Summary:

We obtain your personal data in one or more of the following ways:

• You directly provide it to us by manually inputting it into one of our apps (example: your name, mobile number, payment method), when you enquire with us about our products and services, when you ask us to provide you with a product or service, or when you ask another party like a property sales or letting agency or one of our subsidiary companies to share your data with us.
• You authorise a third party to provide it to us (example: new-build housing developments and developers share information with us about purchasers to allow us to transfer over supply unless the purchaser switches to another electricity supplier.)
• We automatically record it from a network device (e.g. budget controller, smart meter, EV charger), when you use our products or services, including energy usage data, making transactions on your account, how much the payments are for and when the payments are made.

Categories of Personal Data We Process

The specific types of personal data we process about you may vary depending on the specific product or service you are using. Examples or descriptions of categories of data provided here are not exhaustive and are for information purposes. Supplemental information will be provided to users for specific contexts where necessary.

Category	Example / Description	Source
Identity Information	First Name Last Name Email address	Directly Provided
Financial data	Credit cards Debit Cards Bank account details Provided to make payment for the products and services you purchase from us	Directly Provided
Survey Responses	To ascertain customer satisfaction	Directly Provided
Location	Postal address GPS co-ordinates of an installation location	Directly Provided
Activity Data	Smart meter data where you have given consent or where you enter into a contract for services which Smart Meter data. (this includes electricity consumption and carbon emissions) Electronic vehicle charge data Meter and energy consumption information (information about your bill pay meter and energy consumption)	Automatically recorded
Technical Data [This is indirectly personal data as it can be associated to a service user or supply device]	Device type Features used in application Logs of date/time of interaction Details of app crashes or failures Energy supply data (e.g. usage from network and usage from solar panels)	Automatically recorded

In addition, photographs are taken of the installation location as part of site surveys and of all electrical work completed as required by the SEAI grants processes, for safety certification of works, and for insurance purposes. These are retained for the lifetime of the installation.

How Do We Use Your Data (and our Legal Basis for Processing)

Purpose	Legal Basis Relied On
Sale of product or service	Processing is necessary for the performance of a contract to which the data subject is party Legitimate Interest
Product / Service Fulfilment	Processing is necessary for the performance of a contract to which the data subject is party Consent Legitimate interest
Customer Service and Support	Processing is necessary for the performance of a contract to which the data subject is party Legitimate Interest Legal obligation
Technical Support	Processing is necessary for the performance of a contract to which the data subject is party Legitimate Interest Legal Obligation
Analysis of Application performance	Legitimate interests
Proposal preparation	Legitimate interest Necessary for the purposes of a contract entered into by the data subject or in order to take steps at the request of the data subject prior to entering into a contract
Marketing	Consent Legitimate Interest
Statistical Analysis and reporting of aggregated data	Processing for statistical purposes. Safeguards include: Deidentification of data Clustering of data so that no individual installation point or user can be singled out.

 

Categories of Data Processors

Pinergy makes use of several different categories of data processor to help us deliver our services.

• Installation Contractors
  • Pinergy uses 3^rd party contractors to install and maintain budget controllers, meters, or other equipment.
• IT Service Providers
  • Pinergy uses a range of IT service providers to host our systems, develop and maintain software, and support our internal information management processes.
• Infrastructure Providers
  • Infrastructure providers such as the ESB Smart Meter Network or Electric Vehicle charger providers can also process data on behalf of Pinergy to enable us to deliver our products and services.
• Billing, Accounting, and Finance Service Providers
  • We avail of the services of a number of third parties to support our billing processes, our accounting and payments management processes, and our finance and credit control processes.
• Data Protection Officer Services
  • Pinergy has engaged the services of an outsourced Data Protection Officer to support our compliance obligations.

Joint Controller Relationship

Pinergy has entered into a Joint Controller Agreement with our sister company Solar Electric (www.solarelectric.ie). Under this arrangement, Pinergy provide a range of back office and administration supports to Solar Electric.  Both firms engage in cross-sale and bundled sales activities of each other’s related products or services where it is beneficial to our customers.

Under this Joint Controller Agreement, customer information is shared between the two organisations where necessary for these purposes.

Categories of Recipients

Pinergy may provide personal data to the following categories of recipient:

• If you are renting in a property where your landlord or management agency has contracted with Pinergy to provide a pre-paid electricity supply, your landlord will be provided information about the budget controller at your address for the purposes of managing obligations under your lease.
• We provide aggregate statistical information on electricity use in properties to Property Management companies.
• To law enforcement agencies or regulatory authorities on receipt of a valid court order or where expressly required under legislation and only to the extent required by law.
• In the event of a corporate sale, merger, reorganisation, sale of assets, dissolution, or other business-related event, your information may be transferred as part of the assets of Pinergy.

How Long Do We Keep Your Data?

Pinergy retains identifiable data for the duration of your use of our service or use of the application plus any retention period that may be defined by:

• Legal requirements set out in legislation or regulatory guidance in jurisdictions in which our services are provided
• Periods that are reasonably necessary for business and legal purposes.

We will also keep data which cannot directly or indirectly identify living individuals for analytics and research purposes to help improve our products and services.

Cross-border Data Transfers

Third party service providers contracted by Pinergy hold personal data in secure data centres inside the EEA. Where data is transferred outside the EU/EEA, such transfers are carried out on the basis of either:

• Standard Contractual Clauses, or
• An adequacy decision of the European Commission.

In addition, registering user profiles for certain applications provided by equipment providers for certain products may necessitate transfer of your personal data to the UK or other jurisdictions outside the EU/EEA with different data protection regimes to that which applies in Ireland or the EU.

In such cases, your registration for the app may be necessary for the provision of service to you by the equipment provider. They may also require registration of your equipment for warranty or after-sales support purposes.

We regularly review our providers and the basis for any transfers of personal data outside the EEA.

Keeping Your Data Safe and Secure

We place great importance on the security of all personal data associated with our customers. We have security measures in place to attempt to protect against the loss, misuse and alteration of personal information under our control.

Periodic reviews of our security standards are carried out and our software development process has a checkpoint to identify and new risks when we define / develop new features.

However, with any electronic transmission and storage of data comes risks and we cannot guarantee that our databases, or those of our third-party affiliates, will be 100% secure. There is also a risk of data being intercepted while being transferred over the internet.

In the event of a breach of data security, Pinergy will:

• Where we are acting as a Data Controller, we will notify without undue delay the relevant Supervisory Authority where we identify that there is a risk to the fundamental rights and freedoms of people using our applications or services
• Where we are acting as a Data Controller and we identify a high risk to your rights and freedoms we will notify you of the incident without undue delay.

Automated Decision Making and Profiling

The operation of the Pinergy application and smart services require the processing of data for profiling to identify usage patterns in the building and ensure usage information is available.

Profiling and analytics is carried on the basis of half hourly consumption data with consent. If you have not consented to the recording of half-hourly consumption data, this data collected every two months.

No decisions are taken based solely on automated decision making which would have a legal or equally significant impact on a user as the data is used for creating insights on energy consumption.

The exception to this is in the context of pre-pay electricity services where service will be discontinued once the available credit reaches zero or another agreed credit threshold, or post-paid services where an account has outstanding bills. This processing is necessary for the performance of the contract between us as the Data Controller and the data subject as a user of our services.

Your Rights under GDPR

Where Pinergy is acting as a Data Controller, you have rights under EU Data Protection law.  These rights are:

• A right of access which allows you to request a copy of your data in an intelligible form (Article 15 GDPR)
• A right of rectification which allows you to request a correction of errors or inaccuracies in the data that we hold relating to you (Article 16 GDPR)
• A right to object to processing and to “opt-out” of having your data processed by us on the basis of our legitimate interests or a public interest basis unless we can demonstrate compelling legitimate grounds that over-ride your interests, rights, and freedoms. (Article 21 GDPR)
• A right to erasure in certain specified circumstances. This right does not apply where we are processing data for compliance with a legal obligation, for reasons of public interest in relation to public health, for archiving purposes for historical or scientific research, or where necessary to establish or defend legal claims (Article 17)
• A right to restrict processing in certain circumstances (Article 18)
• Under GDPR individuals also have rights to seek compensation for infringement of their data protection rights under the legislation.

Right to Complain to the Data Protection Commission

You have the right to file a complaint to the Data Protection Commission.

Their contact information can be found online at this link: https://dataprotection.ie/en/contact/how-contact-us