Emergent Energy Systems Ltd.

Privacy Policy

Last updated 21.08.25

Our customers are at the heart of everything we do. So, as well as giving you excellent value and great service, we’re committed to protecting your privacy.

This privacy policy relates to Emergent Energy Systems Ltd., the company behind Solar4Flats, and is here to help you understand what data we collect, why we collect it, and what we do with it. Please read carefully, because it tells you some important stuff – about how we handle your personal data, and the steps you can take to look after it.

The responsible data controller is: Emergent Energy Systems Ltd. (10403572).

When we refer to “we”, “us”, and “our”, we mean any this data controller. By “you” or “your” we mean any individual, sole trader and/or partnership that gets products or services from us, uses our website, or interacts with us in another way. This privacy policy supplements, or may be supplemented by, other privacy policies we might give you – but it doesn’t replace them.

If you have any questions, comments, or concerns about this policy, we’d love to hear them. Get in touch anytime: our contact details are below.

Thanks for reading! We hope this policy helps.

We (or third parties who act on our behalf) may collect your personal data when you use our website, talk to us over the phone, by letter, by email, on social media, video, digital messaging (such as WhatsApp or live chat), in person, receive our products and/or services, or ask to join schemes which you’re eligible for. We also may collect information provided by third parties to contact you about our services (See “Marketing” section below).

We might collect the following data:

Your contact details and the contact details of people associated with your account.

Remember: if you give us someone else’s personal data, make sure you always have their permission.

Full name
Email address
Billing address
Property address
Phone number
Any other relevant info we need in order to know that it’s you and be able to contact you directly.
Details of a secondary contact, such as nominees or attorneys (for example, their name and number)

Your account data and the account data of other people associated with your account.

Remember: If you give us someone else’s personal data, make sure you always have their permission.

Unique account number
Date of birth
Title
National Insurance number
Whether you’re a homeowner or renting
Survey responses
Feedback responses (e.g. via our communication platforms, or directly in survey results and trials you have participated in, though these responses will usually be stored anonymously where possible)
Energy Performance Certificate (EPC) data
Photos of your meters
Information about any other accounts you hold for gas or electricity including the name of the supplier and payment methods
Conversations we have with you, including phone calls and emails, which may be monitored or recorded
Household details and property type
Complaints and/or incident details
Appointment details
Notes added to your account

Financial data

Bank account details
Your credit history
Details of state benefits you receive.
Sometimes, details of outstanding debt
Related information that allows us to understand your creditworthiness and financial position, including for affordability assessments.

Technical data

Internet protocol (IP) address used to connect your computer to the internet
Login data (like your username and password)
Your browser type and which version on the browser you’ve got, plus which devices you use to access our websites
Your time zone setting
Operating system and platform
Your behaviours on our website or app (for example, the pages that you click on page response times, download errors, length of visits to pages and how you interact with pages)
Your rough location when you connect to our websites (this will be just the city or county you’re using your device in)
We track technical data by using cookies

Optimisation Data

For some of our products and services we might ask you to give us some extra data about your home and lifestyle, to make sure you get the most out of whatever you are using. This includes data like:
Number of people and rooms in your home
What type of heating system you have

Marketing and communications data

Your marketing and communication preferences in receiving marketing from us and/or third parties, your consent status, and limited contact data (e.g. email, phone number, device/browser info, cookie IDs) we may use to show you digital or direct marketing content

Energy supply data

The date we start supplying your energy
Technical meter details
Meter Point Administration Number (MPAN) for electricity customers
Your plan / tariff
Energy usage (like meter readings and units of electricity used over a period of time)

Sensitive/Special categories of data

Data about your needs and the needs of other people in your household. This helps us understand if you have any special requirements. For example, this data may cover age, disabilities, health and/or any financial vulnerability. And, if it applies to you we might add you to the Priority Services Register.
If we think that someone might have committed fraud or stolen energy from us (for example by tampering with a meter or diverting the energy supply) we’ll record this information

Other

If you want to attend one of our sponsored events, we might need venue and dietary preferences, accessibility needs and an emergency point of contact
If you speak to us through social media, we may take your name and store a link to your social media profile, which we keep with details of your previous correspondence with us.
If you take part in trials, market research, surveys or any related incentive or activity
If you register an account for services with us, we create and record customer ID numbers for you and record the date of your application.
If you consent to video recordings using your camera for virtual home assistance and/or repair, or when we (or third parties who act on our behalf) visit your home wearing a body camera (such as related to debt collection or discussion), we may capture visuals of you, your home or your household. These videos may also be used for safety, training, and service delivery purposes.

Solar4Flats scheme data

If you sign up to a Solar4Flats scheme we will collect your half-hourly usage data for the duration of the service.

Here’s some more information about how we use your data.

Reasons

We might use your data for the following reasons (this can include our agents and third parties too)

To serve your account

To identify you
To give you relevant products and/or services, benefits and rewards
To give you information about the amount of each service you’ve used, and which charges apply. For example, how much electricity you have used and what this will cost
For contacting you about your account, whether that’s via post, email, your online account, SMS, live chat or other forms of electronic communication (including, messages sent through a smart meter) or by visiting you (to take a meter reading for example)
To carry out additional services you have requested.
To assess your financial circumstances in order to offer payment plans and other associated financial and affordability activity. Sometimes we do this using affordability checkers and tools.
To predict the amount of energy you’re likely to use in any period of time
To calculate payments due to you or Emergent
For deciding which products and/or services and which terms and conditions we can offer you.
We will use data collected from your smart meter to work out your bills, to identify you, and to prevent fraud or energy theft.
When you switch to us from your last energy supplier, or when you switch away from us to a new one
To spot and prevent crime, fraud or loss
So you can use interactive online features
As part of arranging and carrying our visits to your property (such as for reading meters)
To give you incentives or run a loyalty scheme
To answer your complaints or questions
To send you relevant marketing messages by email, post, SMS, or phone, depending on your preferences. We may also use your data (such as email address, phone number, or cookies) to show you personalised adverts on social media, platforms, search engines, or other digital platforms. See more about marketing in the relevant section.

To help us improve

For training our team and improving our products and services, which might mean we monitor and record conversations we have with you (like phone calls, emails, SMSs and live chats)
When using data analytics to understand and improve the way we do things as a business
To carry out market research and to get in touch with you about this (for example when doing customer satisfaction surveys and questionnaires)
To create internal reports or profiles while analysing information for forecasting and marketing purposes
When we are conducting trials of technology and infrastructure to help develop and improve products and services
For training AI models which may perform quality and compliance monitoring checks; and assist our customer care agents in providing the services you request.
To create new business models and propositions

To keep in contact

For us (or authorised third parties) to get in touch with you, about our services and/or products - such as to send you info when you sign up or change plans, service announcements and administrative messages
To contact you (by letter, phone call, SMS or email) with details of products and services that we offer, which are similar to those that you have already, or to give you info about services or products you’ve opted in to getting from us
To see if you would like any help when you start but don’t finish our sign up journey, or when you have asked for a quote from us
To contact you about any outstanding matters after the account is closed or you have switched to a different supplier

To support the business

To ensure the health and safety of you, our team and contractors
To comply with any procedures, laws and regulations which apply to us – including where we think it's in our best interests to comply (or in the interests of others)
To allow internal corporate reporting, business administration, adequate insurance coverage, the security of company facilities, research and development, and to find business efficiencies and put these into practise
When your letting agent has given us personal information about you, we might need to share this with your local council and water authority - so they can get in touch with you about any tax or charges
To help with system maintenance, testing and training
To run credit checks and check your credit score, which might affect the services we offer you
To carry out or help with fraud prevention, identity or money laundering verification and legal enforcement when needed
To take payments and go after any money owed to us, and manage our debt collection and recovery activities
To administer and protect our business and to manage and protect our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Where you have voluntarily taken part in a survey, study, or trial of any kind, we will use this information to evaluate the trial and understand its impact. We may also therefore use your information in associated ways, such as prize/incentive distribution, and/or contacting you for additional feedback (unless you have opted-out).
To respond to media or parliamentary enquiries as part of our right to respond

Marketing

We may send you marketing messages about our products and services. This might include:

Postal marketing - sent under our legitimate interests, unless you tell us not to.
Live marketing calls - made under our legitimate interests, provided you’re not on the Telephone Preference Service (TPS) or have not opted out with us.
Emails and SMS marketing - sent only with your consent.

If you decide to leave us, we may contact you to allow us to market our products and services to you after you have left for up to one year, unless you opt out.

You can manage or opt out of marketing at any time.

Service Messages

Not all messages are marketing. We may send service messages to help manage your account - for example, appointment reminders, fixed tariffs ending, safety information, billing updates, or changes to your contracts and/or terms. These are necessary for delivering our services to you and are not affected by your marketing preferences. These service messages might be sent by email and\/or SMS.

Here’s how we use energy consumption data, given to us by your smart meter

We will use your energy consumption data we obtain remotely from your smart meter for the following purposes:

To calculate your energy usage
To produce bills based on real readings
For industry reasons, and to predict the demand for energy
To give you information and feedback about your energy use, as well as how you could manage your energy use better and save money
To track trends in energy use, analyse your energy data, and to compare it over time with other customers’ energy use. This is so we can create tailored products and services for you
To spot faults when they happen and fix these faster, as well as any other issues with your meter
To give interactive tools to analyse your energy use through your online account, or through communications we may send you (like when we send you energy saving advice)
To give you tailored advice on how to lower the amount of energy you use based on your energy use specifically
To carry out internal reporting, modelling and analysis to understand our customers better

Smart meter data

When you join us as a Solar4Flats customer, the default position is that your smart meter will send us half hourly readings for settlement purposes, and daily for billing. This is due to the rules for the scheme applied by Ofgem.

Due to the nature of the Solar4Flats scheme, you are not able to opt out of sharing your half hourly usage data with us. IF you wish not to share this information with us, you will need to be supplied by another energy supplier.

Meter reading frequency information:

Half hourly – your smart meter will collect data every 30 minutes and send this to us once a day

We might also get smart meter readings when:

your prices change
you move to another of our energy plans
you move home
you ask us to
you switch to another supplier

We treat some of the data we collect about you as extra sensitive (also known as ‘special category data’). This could be about your needs, or details of criminal offences. We’ll only use this data in the following ways:

How we look after you and others in your home

We may collect data about you and other people in your household, to make sure we’re aware of any needs you might have. This could be data on age, health, or disability, for example to:

Look after you and others in your household. For example, to make sure we don’t turn off your power if you have a vulnerability. And so we can respond in the right way, if there’s an emergency situation.
Give you products and/or services in a way that suits you, like if you need large print or braille
Assist staff and third-party contractors
Make sure you have the best experience when you come to an Emergent event – let’s say, if we need to make sure the space is easily accessible for you

Criminal offences data

We use details of any criminal offences you’ve been accused of, together with information about whether the gas or electricity supply to your property has been tampered with or stolen in the past (or if we think it has), for the following reasons:

To make decisions about which products and services we can offer you, as well as the relevant terms and conditions
To make decisions about whether to disconnect your energy supply
To spot and prevent fraud or crime, with the help of any third parties when needed

We also get your personal data from the following third-party sources:

Other energy suppliers

Meter readings from your existing supplier, when you ask to switch from us. We might also get details of suspected fraud or energy theft, so we can spot fraud or crime

National databases (ECOES, Xoserve and PAF)

We might get details like your MPAN and other information about your energy supply, to help if you’re going through the process of switching suppliers. And to access this info, we might use a third party.

Debt collection agencies

Information about payments you’ve made or payment plans you have agreed to Information about your personal circumstances such as your ability to pay and any additional needs you have

Credit reference or fraud prevention agencies

For more info about credit references see section “To make credit decisions” below.

Third party data providers

We collect aggregated data about your geo-demographic lifestyle and property energy performance. We analyse this along with your account information so we can gather insights, plan marketing activities to tell you about relevant products and services; and to conduct market research and business development.

If you’ve entered our collections process, we collect contact details to help us get in contact with you

Debt consolidation providers give us information on your debt profile, to help us create payment plans if you’re struggling financially

If we’re doing something that may impact the service you receive, we may ask tracing agents or other third parties to collect your contact details to help us communicate with you

To contact you about our services.

Councils, local authorities or housing associations

We might get your name, address and contact details from councils, local authorities, or housing associations. This could be when we are working with these organisations to deliver a Solar4Flats scheme or planning to delivery one.

Letting agents, landlords, cohabitants, previous tenants or other third parties

We might get your name, address, and contact details if you’ve recently moved into, or taken over a property or supplier. Or if a third party (Like your landlord) introduces you to us.

Ofgem

As a regulated company, we might get your personal information from our regulator, Ofgem, in order to meet our regulatory obligations

Law enforcement agencies (such as the police)

We might get data about meter tampering, the bypassing of meters, or the illegal use of energy so we can spot and prevent fraud or crime

Third parties who introduce you to us

If you are introduced to us by a third party, we will obtain the personal data you provided to a third party for the purposes of setting up your account and providing you with the services you've asked for.

Third parties who potentially want to sell or disposer the business

We will obtain data from a potential seller or disposer of their business or operations, including due diligence purposes before sale/disposal. This also includes ensuring continuity of energy supply where we acquire your personal data from another energy supplier, whether as a result of a merger, acquisition or business reorganisation.

Third party booking agencies

We may obtain data from a third party for the purposes of booking an appointment.

The legal bases for us to use your personal data are as follows:

For your contract

Our use of your personal data is necessary to give you the products and services that you’ve asked for (for example, energy products) and to provide you with information about these products and services

Our legal obligations

Our use of your personal data is necessary so we can comply with regulatory conditions, government obligations and any other legal requirements.

Our Legitimate Interests

It might be in our interests to collect and use personal data, as we need this info to give you the services you want more effectively. When deciding whether it's in our interests to use your data, we will also consider your interests as a citizen and your rights under data protection laws.

It's in our interests to:

Run, grow, and develop our business
Spot and prevent fraud and identify, exercise or defend ourselves against legal claims, complaints and investigations (including media, parliamentary and regulator investigations)
Make sure our own processes, procedures, and systems are as good as they can be
Recover debts that are owed to us
To support customers in financial difficulty
Get a better understanding of how people use our website and other channels where people engage with us
Analyse and enhance the information that we collect
Work out how effective our promotional campaigns and advertising campaigns are
To send marketing communications to you by Mail and phone. You can opt-out of these at anytime
Enhance, modify, personalise, or otherwise improve our services and communications for the benefit of our customers. If you have concerns about the processing activities based on our interests
Improve the security of our network and information systems
Raise awareness of Smart Meters

Consent

Sometimes, we need your consent if we do want to use your personal data. For example to send you marketing communications about our products in certain circumstances. If you give us consent, but you later change your mind, you may withdraw it, by letting us know. Just get in touch, using the details below and we’ll stop using your data for that purpose.

Vital Interest

On very rare occasions we may use or share data about you to protect you or someone else.

Substantial public interest

If we need to process health related data for providing Priority Services, we may rely on ‘substantial public interest’ as a lawful condition to carry out this processing - in accordance with the Data Protection Act 2018. These interests relate to the safeguarding of people at risk, and safeguarding the economic wellbeing of certain people.

To make credit decisions

We may in the future use automated credit-scoring assessments to check how suitable it is for you to take any product or service on a credit basis, and to manage any debt related to your account. To do this, we might look at:

Data that’s included when you apply for a new product or service
Data we already have about you, your account, or your property – such as payment history for existing products and services. This includes data from accounts where you’re named jointly, with one or more other account holders.
Information from one or more credit reference agency
And/or, where it’s appropriate, data from fraud prevention agencies

If we decide that offering unsecured credit is not appropriate, we might need energy customers to pay a security deposit – or to pay using a prepayment meter, or a smart meter in prepayment mode. We might ask you for payment security at any time, if we decide that unsecured credit is no longer right for you.

We may share your personal data with the following types of third parties:

Our third-party suppliers, partners and subcontractors

They offer, review and/or receive services in relation to our website, services and/or products. They include:

Payment processors
Suppliers of technical, support, and installation services
Insurers
Logistics providers
Call centre service providers
Security providers
Cloud services providers
Research agencies
Market research agencies

Third-party survey and review partners/websites
Customer cash-back reward partners

Industry parties required for Emergent to participate in the energy market

And (If you can claim government funding for energy efficiency measures) installers, energy performance assessors and sales advisors

Family members or cohabitants, previous tenants, landlords, letting agents or other third parties

Where appropriate, people who could need data about you or your property - or who introduced you to us

Government or law enforcement officials

If we have good reason to think we’ve got a duty to do it, we’ll give out your data to meet any legal obligation – where your data might be needed to meet national security or law enforcement needs, or to stop illegal activity.

Other energy suppliers

If you choose to leave us, we’ll share your data with your new supplier to help make the switching process smoother. This includes your energy use and any debts on your account. We might also share your personal data with another energy supplier when they carry out services for us – like if they do meter readings at your property on our behalf.

Regulators or other legally appointed bodies

This includes but is not limited to Ofgem, The Information Commissioner's Office or Financial Conduct Authority. We share your data for legal or regulatory reasons.

Third parties that help us with advertising and marketing

Here’s one example of how this works. We share some personal data with these third parties, who advertise on their platforms for us: Amazon, Meta, Viant, Facebook, and Google AdWords. Wherever possible, your information is hashed, meaning it cannot be read by these partners directly.

Relevant network operators and market operators;

We’ll share data with other utility service providers who might be supplying your property – like your distribution network operator. If you're a Priority Services customer, we may share information with the electricity distributor via the Priority Services Register in line with our supply license obligations. Where necessary, we may do this for providing grid flexibility services, including sharing data with the relevant market operator.

Social services, charities, health care services, and other support service organisations

Where it will help you, we’ll share data with your local authority, water company, social services, charities, healthcare services, emergency responders and other support organisations. We might also share it with housing associations that are relevant to your property and/or your use of our services.

Debt collection and tracing agents

This might happen if you don’t pay us for the services we give you. We might also sell the right to recover any debts you owe us to a third party, which is part of our general terms and conditions for supplying electricity. As well as this, we could pass personal data to possible buyers of this debt, so they can evaluate it before the sale’s complete. If we’re doing something that could impact the service you receive, we may share your personal data with a tracing agent to locate your contact details so we can communicate with you.

Authorised third parties or named account holders

This can be on any account you hold with us

Anyone who buys our business, any other business we buy or merge with, and/or a new data controller

If we sell or merge any of our businesses or assets, or if we do any internal reorganisations, your personal data might be one of the assets that goes to the buyer and/or new data controller. This includes transferring data to a potential purchaser for due diligence purposes before the purchase takes place.

A third party, such as police or legal representative

We would need to share your data with these third parties as part of enforcing our terms and conditions, or any other agreement. This might also happen when we’re replying to any claims, or protecting the following: our rights, or the rights of a third party, or the safety of any person. We might also do this to stop any illegal activity.

Credit reference agencies

When you enter into a contract with us for your energy supply, we may give information about you to credit reference agencies and gather this from them too. If we do, when credit reference agencies get a request from us, they’ll place a search footprint on your credit file. This might be seen by other lenders. They would give us public data (including info from the electoral register), as well as data on shared credit, your financial situation, information on your financial history, and on fraud prevention. We might also make checks, like assessing your application for credit and verifying identities – so we can spot and prevent crime. We’ll also keep sharing information about you with credit reference agencies on an ongoing basis. This includes things like your settled accounts and any debts you haven’t fully repaid on time. Occasionally, we might also do searches via credit reference agencies and fraud prevention agencies to manage your account with us. Who these credit reference agencies are, and the ways in which they use and share personal information, is all explained in more detail at experian.co.uk.

Professional advisers

These advisers could be lawyers, bankers, auditors, and insurers who offer consultancy, banking, legal, insurance and accounting services.

Letting Agents (where applicable)

To carry out any ancillary services that you’ve asked for.

Fraud prevention agencies

(i) To help us spot fraud and energy theft, we’ll give details of your account to fraud prevention agencies, who’ll use the information to check public databases and other ones they hold. They might also give us information to help tackle fraud and energy theft. Checks will be carried out on a regular basis, while you hold an account with us. (ii) If we think or are certain that energy has been stolen, a record will be kept by fraud prevention agencies. This might include sensitive data about alleged criminal offences. The fraud prevention agencies might give the information to other energy companies to help uncover fraud and energy theft, but only in occasional circumstances where you have accounts with them. Where theft has been found, your account terms could change, but we’ll let you know if this is the case

Owners and/or operators of smart (or similar) meters, smart meter contractors and potentially the Data and Communications Company (DCC)

This is for your smart meter, so that we can connect to it and get readings from it.

The ways we protect data when we send it

If we ever need to send data outside of the EEA, we will make sure that all the right safeguards have been put in place to protect your personal data.

This means that we’ll:

Make sure the country where your personal data will be handled has been deemed “adequate” by the Information Commissioner’s Office (“ICO”) in accordance with the UK GDPR.
Include standard data protection clauses (approved by the ICO for transferring personal data outside the UK and EEA) in our contracts with those third parties – these are the clauses approved under Article 46.2 of the UK GDPR.

We keep your personal data for no longer than is necessary. This means that when we don’t need it any more we delete it. The length of time we keep it all depends on why we’re using it and/or what we need to do to comply with applicable laws and to establish, exercise, or defend our legal rights.

In some circumstances, we might anonymise your personal data (so that it can no longer be associated with you) and use this indefinitely, without further notice.

We follow strict security procedures to protect your personal data. This includes following certain guidelines (for example, checking your identity when you phone us).

Whilst we take appropriate technical and organisational measures and have in place physical and electronic procedures necessary to safeguard the personal data that you provide to us, no transmission to or from us by post, email, phone, SMS or over the internet can ever be guaranteed as entirely secure. Communications over the web are not secure and as such, we cannot accept any liability or responsibility for any unauthorised access or loss of personal data.

We also have procedures in place to deal with any suspected data security breach. We’ll notify you and any applicable regulator of a suspected data security breach where we’re legally required to do so.

We may change this privacy policy from time to time. If we make changes, we’ll let you know by revising the date at the top of this policy. If they’re major changes, then we may let you know by getting in touch with you.

Our contact details are in below, and you can always get in touch to ask that we:

Let you know if your personal data is being processed
Give you further details about how we process your personal data
Give you a copy of any personal data we hold about you
Withdraw your consent for a way that we’re using your data (where we need your consent legally to use your personal information)
Consider any valid objection you have to us processing your personal data (including the right to object to processing where we’re relying on our interests as a legal basis for processing)
Update or delete personal data that we have about you
Restrict the way that we process your personal data
Consider any valid request to transfer your personal data (that relates to an energy account) to a third-party provider of services (this is called data portability)
Where we carry out automated decision making that has legal or significant effects on you, make sure we get a person to review that decision, give you an explanation of the decision, and/or consider your appeal of the decision

Exemptions

However, certain personal data may be exempt from the requests above, in certain circumstances. We could need to keep processing your personal data because of our interests, or to meet a legal obligation.

Response

If an exemption applies, we’ll tell you when we reply to your request. We might ask you to give us some data to confirm your identity before we reply.

Our contact details

Two tips to help us get back to you more quickly:

When you send us your message, let us know if it's a "rights request" as part of your message. This will help us make sure it gets to the right people.
Include your name, account number, address, and if there's any data you're especially interested in, if you can. This will make it easier for us to respond to you properly.

How to contact us:

If you’ve got any questions about data protection, or you’re not happy with how we’ve handled your data, email us at decarbonise@emergent.energy

Third party requests for information

Please also use the contact details provided above.

Data Protection Officer (DPO)

You can email our Data Protection Officer (DPO) at decarbonise@emergent.energy.

You can also write to them:

86-90 Paul Street, London, EC2A 4NE

Information Commissioner’s Office (ICO)

If you’re not happy with our reply to any complaint or you think our processing of your data doesn’t comply with data protection law, you can make a complaint to the Information Commissioner’s Office (ICO). Just use these details:

Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Telephone number: 0303 123 1113
Website: ico.org.uk