Privacy Policy

We are Wondrwall Ltd (registered in England with company number 09259583) (as Data Controller), Wondrwall Group Ltd (registered in England with company number 11077377) , it’s trading subsidiary, Wondrwall Analytics Ltd (registered in England with company number 11077377) and it’s other trading subsidiary Wondrwall Energise Limited (registered in England with company number 06618154) each of whom may be Data Processors or Data Controllers depending on the purpose) (collectively we or us). Our registered office and main trading address at Tower 12, 18-22 Bridge Street, Manchester, M3 3BZ, United Kingdom.

We are committed to protecting and respecting your privacy.

This policy explains the basis upon which we use or “process” any personal data which we collect from you, which you provide to us or which may be provided to us by third parties or from any third party accounts which may link to our application, and the choices which you can make about the way in which that information is collected and used. To better protect your privacy and make this notice easy to find, we make it available from our app and at every point at which we may request personal information from you.
Please read this policy, and any document referred to in it carefully to understand how we and our trusted partners use your personal data and protect your privacy.

The Terms of Use and other documents provide details of the basis for the use of the App.

Data Controller / Data Processor

Controller

The Data Controller is the party who is ultimately responsible for the use of personal data and who has the legal right to use it. Wondrwall Group Ltd will be the controller of personal data being processed for the Wondrwall business, this is for its own means and purposes. This will include any data we obtain from you that we use for billing, managing our relationship with you, the data we obtain to help us improve our services and any data that we use for things like marketing and analytics (see the section below titled “Information which we collect” and “Uses made of your information” for further information).

Data Processor

In some circumstances, Wondrwall Group Ltd may be only a processor of your personal data. This will be where we process personal data for someone else such as your landlord. Where we are a data processor the party who acts as the data controller should provide you with a privacy notice which will confirm how they collect and use your personal data as well as the basis on which they are able to do this.

As noted above, other Wondrwall companies may also be processors of data on behalf of Wondrwall Group Ltd from time to time.

Third Party Controllers

In certain circumstances we may share your personal data with trusted third parties. We will only do this where we have a lawful basis to do so. The lawful basis we rely on include:
• Where there is a legal requirement to share your personal data (e.g. because we are required to by law);
• Where we have legitimate interests to share your personal data and you have been informed of the purpose for sharing the data.
• Where you provide your consent to your data being shared with those third parties.

Where we share your personal data with third parties using one of the lawful basis mentioned above, those third parties will be independent controllers (or sometimes joint controllers) of your data, where they decide the means and purposes of processing your personal data (or jointly determine the means and purpose of the processing with Wondrwall Analytics Ltd).

Where we act as a data processor and share data with landlords, property managers, local authorities and housing associations (who are independent controllers of your personal data), those third parties should provide you with separate notices in relation to the data being shared, the purposes for processing your personal data, the lawful basis for processing and your legal rights as they relate to that processing.

See the “Uses made of the information” and “Disclosure of your information” sections below for further information.

Information which we collect from you

We will collect the following types of personal data about you (or others in your home):
• Identity Data: first name, last name, username or similar identifier, title, date of birth, gender.
• Contact Data: billing address, delivery address, email address and telephone numbers.
• Financial Data: bank account and payment card details.
• Transaction Data: includes details about payments to and from you.
• Device Data: includes the type of devices in your home you use, the devices that provide data to us, a unique device identifier for the devices providing data to us and [information recorded on the device (see Content Data).
• Content Data: includes information recorded and/or stored on your Device or which your Device transmits to us, including data we refer to as Habitational Data, Environmental Performance Data and Energy Data. Habitational Data includes data about when people leave home, arrive at home and where they move to around the home. Environmental Performance Data includes data about how warm the home is, how bright the environment is, humidity levels and any changes to this type of data. Energy data is data about the energy being generated by the home, how much is being consumed, battery levels and similar data. These types of data are monitored when they change or based on predetermined timings.
• Profile Data: includes your username and password, your interests, preferences, feedback and survey responses.
• Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, website and online chat details.
• Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Location Data: includes details obtained from the usage data.

We also collect, use and share aggregated data such as statistical data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Content Data to calculate the percentage of users who use particular services. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy. We do not collect any special category of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health, genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How we collect your information

We will collect and process the following data about you:

Information which you give to us. This is information about you that you give us by filling in forms on our app or by communicating with us by phone, e-mail or otherwise (including via social media). It includes information you provide when you register to use our app and our services, search for a product or place an order on our app, and when you report a problem with our app and/or our services. The information you give us may include, and is not limited to, your name, address, email address and phone number, financial and credit card information and internet protocol (IP) address used to connect your device to the internet and access our app.
On some pages, you can submit information about other people. For example, if you order a product online and want it sent directly to the recipient or you wish to add or link people to your account(s), you will need to submit the recipient’s address and contact details. In this circumstance, the types of personal information which we will collect are name, address, phone number, email address. We will not use any data which you may provide about any third party to send them any marketing or other communication unless and until they register to use our app and/or our services, save that we may send them an email to confirm they wish to be linked to your account.

Information which we collect about you. We collect information from your use of the App, from your mobile device and your use of our devices we will collect the following information:
• location data from your mobile device and any linked mobile devices, (where permission is provided for the Wondrwall App to access location data and you have provided your consent for Wondrwall to process this data for its own purposes). This data includes data in relation to how you use our geofencing services;
• technical information, including (without limitation) the type of mobile device you use to access our app, a unique device identifier (for example, your device’s IMEI number, the MAC address of the device’s wireless network interface, and/or the mobile phone number used by you device), mobile network information, your mobile operating system, the type of mobile browser you use, or time zone setting, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform etc;
• information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our app (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number;
• information from devices linked in your property.

Information which we receive from other sources. This is information we receive about you if you use any of the websites or other applications we operate or the other services we provide or from manufacturers we work with or from other accounts (e.g. Amazon) you link to your Wondrwall account in respect of products purchased from them. We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

Cookies

Our app uses cookies to distinguish you from other users of our app. This helps us to provide you with a good experience when you browse our app and also allows us to improve our app. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy https://wondrwall.com/cookie-policy/.

Uses made of the information

We use information held about you in the following ways both to enable us to provide the Wondrwall App and other services to you. These are categorised depending on our legal reasons for doing so:
• Consent – this is where you provide your permission for us to use this data;
• Legitimate Interests – this is where we have legitimate interests as a business in undertaking certain tasks;
• Performing our contract with you – this is where we undertake tasks to deliver the app, services and other responsibilities to you; and
• Legal Requirement – Where we have a legal requirement to process your data.
Where this is based on your consent, you can withdraw this any time, please see the section entitled “Your Rights” below but in some cases we will be unable to continue to provide the app and/or services to you).

Social login details

We may allow you to create, authorise and sign into our app using a third party platform such as Amazon, Twitter and/or Facebook. By using those third-party services to do so, you confirm that you agree to their terms of use, privacy policy and any other agreements or documents which set out the terms of your relationship with them and use of their services, which is separate from your relationship with us and your use of our app and authorise us to share your personal data with any third party website or app provider to which your account is linked. You also authorise us to retrieve and/or receive and/or access your personal data held by any third party website or app provider to which your account is linked which is relevant to our app and services, and agree to the transmission, storage, processing and use by us of your personal data retrieved and/or received from any third party website or app provider to which your account is linked in the manner set out in this Privacy Policy. This paragraph of this policy applies in relation to personal data that is held by any third party website or app provider and that is retrieved and/or received by us or is otherwise transmitted to us and such personal data constitutes user submitted or generated content which is uploaded, posted or otherwise transmitted to us.

Insurance services

We may provide, or partner with companies which provide, home insurance products to you. In such circumstances we will use the information we have collected about you and your property to check against information provided by you, and share your information with such insurance providers to enable them to check against information provided by you in relation to the tailoring of quotes for and provision of such services, to monitor compliance with the terms of any insurance policy issued to you or in respect of the property where the Wondrwall products are installed. We, or a partner provider of insurance, may also use your information for the following reasons:

• to assess your suitability for an insurance product based on the information Wondrwall has about your property and its use;
• to submit an application on your behalf to one or more insurance company to enable us to obtain a quote;
• to assess your financial suitability;
• to prevent fraud;
• to verify the provided information;
• to maintain your records with the insurers;
• to advise you on available products; and
• for monitoring and compliance purposes.

Disclosure of your information

We will share your personal information or derivatives of it with:
Wondrwall Ltd, Wondrwall Insure Ltd and their related companies for product registration and commercial support purposes.
Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 from time to time.
Selected third parties including:
• business partners, payment service providers, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
• the provider of any third party account which you link to your account, such as Amazon;
• the provider of any insurance policy, including underwriters of such policy, for the purposes of maintaining compliance with the terms of a relevant policy and/or advising you in respect of available insurance products;
• advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, persons within a certain age bracket in a specific geographic area). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;
• analytics and search engine providers that assist us in the improvement and optimisation of our app and our services;
• credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
• Trusted third party landlords, property managers, housing associations and local authorities, in order for them to provide their property management services (for example property energy management – luminosity, heating, etc.) and fulfil their obligations to you and the wider community (for example, to monitor for fuel poverty, damp, humidity levels, etc.).

We will disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
• If we or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• 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 enforce or apply our terms of use or terms and conditions of sale and other agreements; or to protect the rights, property, or our safety or the safety of our customers, our customers, staff and suppliers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
• In respect of products ordered, to the manufacturer of such products.
• In order for those third parties to provide their services / fulfil their obligations to you (for example, landlords, property managers, housing associations and local authorities).
• In order to market either our or our trusted third party products and services, or for those third parties to market directly to you where you have provided your consent.

We use the information you provide about someone else when placing an order only to deliver the product and confirm delivery. We do not share this information with third parties except to the extent necessary to complete that order.
We use return email addresses to answer the email we receive. Such addresses are not used for any other purpose and are not shared with third parties other than our suppliers, subcontractors and members of our group and for the purposes set out in this policy.
Finally, whilst we may use your personal information for related purposes to those above, we never use or share the personal information provided to us in ways unrelated to those described above without also providing you with an opportunity to confirm your consent to such use.

Where we store your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”), including the United States of America. It will also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Security

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access our app and our services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our app and our services; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
To prevent unauthorised access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online. Access to the information which you have provided will be limited to authorised employees as required for the purposes identified above as well as IT security and maintenance.
Any personal information you provide may be used to verify your identity and assist us in preventing or detecting fraud. As part of these checks your information may be disclosed to credit reference agencies, who may keep a record of that information.

Retention of your data

We will retain your personal data on our systems for as long as you continue to use our devices and services. This is based upon our need to maintain a record of your personal data for the purposes set out in this policy and based upon the period of limitation in any legal claim (in relation to which we may need access to or be compelled to disclose personal data relating to you) being a maximum of 6 years after last use of the services or app or contact with us.

Your rights

You have the right to:
• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
(a) if you want us to establish the data’s accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Access to your information

Data protection law gives you the right to confirmation that we are processing your personal data and to access information held about you, subject to some exceptions. Your right of access can be exercised by writing to The Data Protection Officer, Wondrwall Ltd, Tower 12, 18-22 Bridge Street, Manchester, M3 3BZ, United Kingdom. Any access requests are usually free of charge, however we reserve the right to charge a fee where we are entitled to do so by data protection law.

Changes to our privacy policy

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to hello@wondrwall.co.uk. You can also write to us at: Tower 12 18 – 22 Bridge Street, Manchester, M3 3BZ, United Kingdom.

Version number and date

Privacy Policy version number 2024 Wondrwall Privacy Policy V4