Privacy Notice & Transparency Statement

1. Introduction

Pinn Partners respects your privacy and is committed to protecting your personal data. This Privacy Notice explains how we collect, use, store and share personal data when you contact us, use our website, become our customer, receive our services, or otherwise interact with us.

This notice is provided in accordance with the UK GDPR and the Data Protection Act 2018. Individuals have the right to be informed about the collection and use of their personal data. This is a key transparency requirement under the GDPR.

ICO guidance on the Right to be Informed: ico.org.uk — Right to be Informed

2. Who we are

Pinn Partners provides business services including energy, EV & solar, payment solutions and retail technology support. For the purposes of data protection law, Pinn Partners is usually the data controller of the personal data we collect and use.

Organisation name	Pinn Partners
Legal entity	Pinn Partners Ltd
ICO Reg Number	ZA737239
Company number	11089957
Registered office	Building 3, North London Business Park, Oakleigh Road South, London N11 1GN
Trading address	Building 3, North London Business Park, Oakleigh Road South, London N11 1GN
Website	www.pinnpartners.net
Email	contact@pinnpartners.net
Telephone	0333 090 9040

3. Data protection contact

If you have any questions about this Privacy Notice or how we use your personal data, please contact:

Data protection contact	Data Protection Team
Email	contact@pinnpartners.net
Postal address	Building 3, North London Business Park, Oakleigh Road South, London N11 1GN
Data Protection Officer	Not applicable

4. UK/EU representative

Pinn Partners is based in the United Kingdom.

• UK representative: Not applicable, unless otherwise stated.
• EU representative: Not applicable unless we actively offer services to individuals in the EU or monitor individuals in the EU. If this changes, we will update this notice.

5. What personal data we collect

Depending on your relationship with us, we may collect and use the following types of personal data:

Category	Examples
Business contact details	Name, job title, business name, business address, email address, telephone number and preferred contact method.
Service and contract information	Information about your business requirements, current suppliers, contract dates, renewal dates, utility supply details, energy or water usage, meter numbers, supply numbers, payment solution requirements, EPOS/retail technology requirements and related documents.
Identity and authority information	Information needed to confirm that you are authorised to act for your business, including letters of authority, signed forms, business records and communications.
Communication records	Emails, call notes, messages, meeting notes, enquiries, complaints, customer service records and CRM notes.
Financial and billing information	Invoice details, payment records, commission records, account references and accounting information. We do not intentionally collect payment card details through our website unless clearly stated at the point of collection.
Website and technical information	IP address, device information, browser type, website usage data, cookies and analytics information.
Marketing preferences	Your preferences about receiving marketing communications from us and records of consent or opt-out requests.
Information from third parties	Information from suppliers, brokers, partners, comparison services, referral sources, public business directories, Companies House, online business listings or your employer/business.

6. Why we use your personal data and our lawful basis

We only use personal data where we have a lawful basis to do so. The lawful bases we may rely on include consent, contract, legal obligation and legitimate interests.

Purpose	Personal data used	Lawful basis
To respond to enquiries	Name, business details, contact details, enquiry information	Legitimate interests / steps before entering into a contract
To provide quotes and proposals	Contact details, usage details, supply details, contract details	Contract / legitimate interests
To arrange energy, water, payment or retail technology services	Business details, supply information, signed authority forms, contract information	Contract / legitimate interests
To manage customer accounts	Contact details, contract details, renewal dates, service records	Contract / legitimate interests
To contact suppliers or partners on your behalf	Business details, supply numbers, authority documents, contract information	Contract / legitimate interests
To send renewal reminders and service updates	Contact details, contract dates, service history	Legitimate interests
To send marketing to business contacts	Contact details, business sector, service interests, marketing preferences	Legitimate interests / consent where required
To improve our website and services	Website usage data, analytics data, feedback	Legitimate interests / consent for non-essential cookies
To comply with legal and accounting obligations	Invoice records, contracts, communications, business records	Legal obligation
To prevent fraud and protect our business	Contact details, account records, technical data, communications	Legitimate interests / legal obligation
To handle complaints or disputes	Communications, service records, contracts, evidence documents	Legitimate interests / legal claims

ICO guidance on lawful basis: ico.org.uk — A guide to lawful basis

7. Legitimate interests

Where we rely on legitimate interests, our interests include running and improving our business, providing services to commercial customers, managing supplier relationships, keeping accurate records, preventing fraud, sending relevant business communications and protecting our legal position.

We will not use your personal data where your rights and freedoms override our interests. You have an absolute right to object to direct marketing at any time.

8. Marketing communications

We may contact business customers, prospective customers and business contacts about relevant Pinn Partners services, including energy, EV & solar, payment solutions and retail technology.

You can opt out of marketing at any time by emailing contact@pinnpartners.net, calling 0333 090 9040, or using the unsubscribe link where available in our emails.

9. Cookies and website analytics

Our website may use cookies and similar technologies. We use essential cookies to make the website work. We may also use analytics or marketing cookies to understand website usage and improve our services.

Where required, we will ask for your consent before placing non-essential cookies. A separate Cookie Policy is available on request and will be published on this website.

10. Where we get personal data from

We may collect personal data:

• directly from you when you contact us, complete a form, sign a document or become a customer;
• from your business, employer, colleague or authorised representative;
• from suppliers, brokers, referral partners or service providers;
• from public sources such as Companies House, business directories, websites and online listings;
• from email, telephone, website forms, meetings, CRM systems and business records.

11. Who we share personal data with

We may share personal data with the following categories of recipients where necessary:

• energy suppliers;
• water suppliers;
• EV, solar, payment and retail technology providers;
• metering agents, consultants, brokers and partner organisations;
• CRM, email marketing, website, hosting, IT and cloud service providers;
• accountants, bookkeepers, auditors and professional advisers;
• legal advisers, insurers and debt recovery providers;
• regulators, law enforcement bodies, HMRC, courts or public authorities where required;
• prospective buyers, investors or advisers if our business is reorganised, sold or merged.

We only share personal data where it is necessary and lawful.

12. International transfers

Some of our service providers may process personal data outside the UK. Where this happens, we will ensure appropriate safeguards are in place, such as UK adequacy regulations, approved contractual safeguards or other lawful transfer mechanisms.

You can contact us for more information about international transfer safeguards.

13. How long we keep personal data

We only keep personal data for as long as necessary for the purposes set out in this Privacy Notice.

Type of record	Usual retention period
Customer contracts and account records	Up to 7 years after the end of the customer relationship
Quotes and enquiries that do not proceed	Up to 24 months
Letters of authority and supplier correspondence	Up to 7 years after the relevant service ends
Accounting and tax records	Usually 6 years plus the current accounting year
Marketing records	Until you opt out or we no longer need the data
Suppression/opt-out records	As long as needed to respect your opt-out
Website analytics data	14–26 months
Complaint and dispute records	Up to 7 years, or longer if needed for legal claims

14. Your rights

You have rights under data protection law, including:

• the right to be informed about how we use your data;
• the right of access to your personal data;
• the right to rectification if your data is inaccurate or incomplete;
• the right to erasure in certain circumstances;
• the right to restrict processing in certain circumstances;
• the right to data portability in certain circumstances;
• the right to object to processing, including direct marketing;
• rights relating to automated decision-making and profiling.

To exercise your rights, please contact us using the details in section 3. We may need to verify your identity before responding. We will normally respond within one month, unless the request is complex or we are permitted to extend the response period.

15. Right to withdraw consent

Where we rely on your consent, you have the right to withdraw that consent at any time. Withdrawing consent does not affect the lawfulness of any processing carried out before consent was withdrawn.

16. Are you required to provide personal data?

In most cases, you are not under a statutory obligation to provide personal data to us. However, where you want us to provide quotes, arrange services, manage contracts, contact suppliers or support your business, we may need certain personal data to provide those services.

If you do not provide the required information, we may not be able to provide our services. In some cases, we may need to process certain information to comply with legal, tax, accounting or regulatory obligations.

17. Automated decision-making and profiling

We do not make decisions about you based solely on automated processing that produce legal or similarly significant effects.

We may use basic CRM segmentation or profiling to understand customer needs, manage renewal reminders, identify relevant services and send appropriate business communications. This does not involve fully automated decision-making with legal or similarly significant effects.

18. Security

We use appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse, alteration or disclosure. Access to personal data is limited to people who need it for business purposes.

19. Complaints

If you are unhappy with how we handle your personal data, please contact us first so we can try to resolve the matter.

You also have the right to complain to the UK supervisory authority:

Supervisory authority	Information Commissioner's Office
Address	Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Website	ico.org.uk/make-a-complaint
Telephone	0303 123 1113
Notes	You may complain to the ICO if you are dissatisfied with our response.

20. Changes to this Privacy Notice

We may update this Privacy Notice from time to time. The latest version will be posted on our website. Where we make significant changes, we will take reasonable steps to bring them to your attention.