INTRODUCTION

1. This Privacy Policy explains how the London Energy Brokers’ Association (“Greenfrog Systems Ltd”, “we”, “us” or “our”) collects information from you when you visit or register to use any of Greenfrog Systems Ltd Website) and how this information is then used.  If you have any questions about this statement or your personal information that we may collect from you, please contact us using the “Contacting Us” section below.
2. Please read this Privacy Policy carefully and re-visit this page from time to time to review any changes that may have been made.
1. DATA PROTECTION ACT 1998
1. At all times we are legally obliged to collect, retain and process any personal information that you provide in accordance with the Data Protection Act 1998.
1. [We are registered as a data controller in accordance with the Data Protection Act 1998.  We will process any personal information we collect about you in accordance with the Data Protection Act 1998.]
2. This Privacy Policy applies to you whether you use the Website as a casual browser, or have registered to use the Website or have entered into a contract with GREENFROG SYSTEMS LTD in relation to the supply of specific services and/or products. In the event of any conflict between this Privacy Policy and the terms of a contract you have with GREENFROG SYSTEMS LTD, the relevant provision of that contract shall prevail to the extent of any inconsistency.
2. PERSONAL INFORMATION COLLECTED AND HOW IT IS USED
1. Information collected when you browse the Website
2. We may collect and process the following data about you:
1. Information you provide by filling in forms on the Website.  We may also ask you for information when you report a problem with our site.
2. If you contact us, we may keep a record of that correspondence.
3. We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
4. Details of your visits to our site including but not limited to, traffic data, location data, weblogs and other communication data.
5. [Describe any other types of information collected.]

[Note: GREENFROG SYSTEMS LTD will need to ensure that consent is obtained when personal data is collected.  In the case of “personal data” (i.e., any data which relates to a living individual who can be identified from those data or from those data and other information which is in the possession of, or is likely to come into the possession of, the data controller) a link to this privacy policy or a tick box should be sufficient.  In the case of “sensitive personal data” (i.e., data consisting of information as to racial or ethnic origin, political opinions, religious beliefs or beliefs of a similar nature, trade union membership, physical or mental health or condition, sexual life, criminal offences etc.) express consent will be necessary via a ‘tick box’.  We are happy to advise you on the specific wording for such a tick box should you wish.].

1. Uses of personal information that we collect
1. Where we collect personal information, we will use it for administration and to tailor our service and/or products to match your needs. We may also use personal information to conduct market research surveys, for statistical analysis to determine site usage, to run competitions and for direct marketing purposes relating to our business.
2. We may employ the services of a third party to help us in certain areas, such as website hosting, marketing and market researching. In some cases that third party may receive your information. However, at all times we will control and be responsible for the use of your information.
3. The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). By submitting your personal data, you agree to this transfer, storing or processing.
2. Disclosure of personal information
1. We may disclose your personal information to third parties 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 above and other agreements; or to protect the rights, property or safety of GREENFROG SYSTEMS LTD, our Members, or others.  This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
3. Your Rights
1. You have the right to ask us not to process your personal data for marketing purposes.  We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.  You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data.  You can also exercise the right at any time by contacting us using the “Contacting Us” section below.
2. The Data Protection Act 1998 gives you the right to access information held about you.  Any access request may be subject to a fee of [£10] to meet our costs in providing you with details of the information we hold about you.

Should you wish GREENFROG SYSTEMS LTD to cease marketing to you, or to update, correct or delete your personal information as appropriate you should contact us using the “Contacting Us” section below.

1. STORAGE OF YOUR PERSONAL INFORMATION
1. We will hold your personal information securely and will only keep it for as long as is reasonably necessary.  We take the security of the Website and the information you provide very seriously and we will take appropriate technical measures using recognized security procedures and tools in accordance with good industry practice to protect your personal information.
2. Whilst we use all reasonable endeavours to protect your security in the manner described above, we consider that it is only appropriate to advise users that data transmission over the Internet and the World Wide Web cannot always be guaranteed as 100% secure, and therefore that you use the Website at your own risk.
2. IP ADDRESSES AND COOKIES?

[Note to GREENFROG SYSTEMS LTD:  do you use any technology to track the numbers of visitors etc. to your website?  If so, we will need to include this clause relating to “cookies” (information stored on a user’s computer often used to recognise those who have previously visited a website).  If you do not use this technology, please delete this section (IP ADDRESSES AND COOKIES).]

1. Your Internet browser has a feature called "cookies" which store small amounts of data on your computer about your visit to the Website.  A cookie does not provide us with any personal information. Therefore, if you have not supplied us with any personal information, you can still browse our site anonymously.
2. [We do not automatically capture or store personal data from browsers to the site, [other than to log your IP address and session information such as the duration of the visit to our site and the nature of the browser used]. This information is used only for administration of the site system and in the compilation of statistics used by GREENFROG SYSTEMS LTD.]
3. Cookies may be required to allow you to access and participate in certain areas of the Website. Once you have closed your browser, this type of cookie is deactivated.
4. [Insert any other uses that GREENFROG SYSTEMS LTD may make of cookies].
5. The majority of browsers will allow you to alter the settings used for cookies and to disable and enable them as you require. If you do not want cookies then please refer to the help menu on your browser for instructions on disabling them.
1. CHANGES TO THIS PRIVACY POLICY
1. If we make any changes to this Privacy Policy these changes will be detailed on this page in order to ensure that you are fully aware of what information is collected, how it is used and under what circumstances it will be disclosed.
2. LINKS
1. This Privacy Policy applies only to information collected by this Website.  The Website may contain links to other websites. Please be aware that we are not responsible for the privacy policies of such other sites and we would advise you to read the privacy statement of any website that collects personal information from you.
3. CONTACTING US
1. Questions comments and requests regarding this privacy policy are welcomed and should be addressed to: info@greenfrogsys.co.uk