This page is a structural draft for solicitor review. It is not final legal advice and must be replaced before launch.
1. Who we are
Version: 0.1 (draft). Last updated: [DATE].
1.1 This policy explains how [COMPANY NAME] ("EV Tariffs Compared", "we", "us") uses personal information on evtariffscompared.com (the "site").
1.2 Company number: [COMPANY NUMBER]. Registered office: [REGISTERED ADDRESS].
1.3 We are registered with the Information Commissioner's Office (ICO). Registration number: [ICO REGISTRATION NUMBER].
1.4 To contact us about your information, email hello@evtariffscompared.com. We have not appointed a data protection officer because we are not required to. That email address is our privacy contact.
2. Who is responsible for your information
2.1 We are the "controller" of the information described in this policy, which means we decide how and why it is used.
2.2 When you ask for installer quotes and we pass your details to installers, each installer that receives them becomes a separate controller for its own use of those details (see section 7). We are not responsible for what an installer does with your details after they receive them, but we ask each installer to agree to protect them and to use them only to respond to your request.
3. What information we collect, why, and our legal basis
The law requires us to have a "lawful basis" for each use of personal information. This table shows what we collect, why we use it and the basis we rely on.
| What | Why we use it | Lawful basis |
|---|---|---|
| Quote request details: your name, email address, telephone number, postcode and the area you live in, details about your charger, property and vehicle, your timeframe and budget range, notes and any photos you add | To understand your request, match it with suitable installers and pass it to them so that they can quote | Your consent, for sharing your details with installers (UK GDPR Article 6(1)(a)). Legitimate interests (Article 6(1)(f)) for running the matching service and keeping records of requests |
| Record of your consent: the wording you agreed to, the time, and the installers it covered | To show that you agreed to share your details and what you agreed to | Legitimate interests (keeping evidence). Legal obligation where the law requires us to show consent |
| Postcode lookup: the postcode you enter | To work out your area, installer coverage and tariff regions. The postcode is checked with the postcodes.io service from our servers | Legitimate interests (providing the service you ask for) |
| Newsletter details: your email address and when you confirmed | To send you the newsletter, using a confirmation email to check it is you | Your consent (Article 6(1)(a)) |
| Messages to us: the details you give when you email or use the contact form | To reply, help you and keep a record | Legitimate interests (answering enquiries). Contract, if you are an installer or applicant |
| Installer applications and installer accounts (these may be personal data where an installer is a sole trader or names an individual): business and contact name, email, telephone, postcode, registration body and number, grant approval number, areas covered, insurance details, and information from our checks | To assess applications, check registrations and insurance, run the installer account, manage plans, credits and leads, and keep records | Taking steps before a contract and performing the contract (Article 6(1)(b)). Legitimate interests (checking installers are who they say and are suitable to be listed) |
| Payment details of installers: Stripe handles card details. We receive confirmation of payment, amount, customer reference and invoice or receipt details, not your full card number | To take payment for credits and plans, issue receipts and invoices, and keep financial records | Performing the contract. Legal obligation (accounting and tax records) |
| Email delivery information: that an email was sent, delivered or bounced and, where you have agreed to analytics, whether it was opened | To send the emails you ask for and to keep the service working | Legitimate interests (making sure emails arrive). Your consent for any open tracking |
| Technical and security data: IP address, browser and device information, pages requested, bot-check results and error reports | To keep the site secure, block abuse and automated submissions, find and fix errors | Legitimate interests (security and reliability) |
| Cookie and consent choices: your cookie choices and a random browser reference | To remember your choices and show we respected them | Legitimate interests and legal obligation (keeping evidence of consent). See the Cookie Policy |
| Analytics data: how you use the site, collected by analytics cookies | To understand how the site is used and improve it | Your consent (Article 6(1)(a) and the cookie rules). Nothing is collected unless you accept analytics cookies |
| Reviews and review evidence (only if review collection is switched on): your review and the information needed to check it is genuine | To publish checked reviews and prevent fake reviews | Legitimate interests. No review scores or star ratings are shown at launch, so this applies only if review collection is switched on. |
| Complaints and requests about your rights | To investigate and reply | Legal obligation, and legitimate interests |
| Outbound clicks: when you click through to a supplier's tariff page we record which tariff and link type was used, not who you are | To understand which tariffs and links are used | Legitimate interests |
3.2 You do not have to give us your personal information, but we cannot send a quote request to installers without the details marked as required on the form.
3.3 We do not intentionally collect information about children. The site is not designed for anyone under 18.
3.4 We do not ask for special category data (such as health information). Please do not include it in notes or photos. Photos can sometimes show people or other personal information, so please share only what is needed.
4. Where we get information from
We get most information directly from you. We also receive information from:
- the postcodes.io service (area information for the postcode you give us);
- Stripe (payment confirmations for installers);
- public registers and scheme bodies, Companies House and installers' insurers, when we check installer applications;
- installers, where they tell us the outcome of a quote request (for example for a credit-back request or a review).
5. How matching and decisions work
5.1 When you ask for quotes, we use a computer system to choose which installers to offer your request to. It uses things such as your location, the areas an installer covers, the type of job and installer availability. Installers decide for themselves whether to accept.
5.2 This does not produce a decision that has a legal effect on you or similarly significantly affects you. A person at EV Tariffs Compared can review a matching problem if you contact us.
6. Marketing and email
6.1 We send the newsletter only if you ask for it, using a confirmation email. You can unsubscribe at any time using the link in every email or by emailing us.
6.2 We use your quote request details to deal with that request and send service emails about it (for example to confirm it was received or to let you manage it). We do not use them to send you marketing unless you have separately agreed.
6.3 At launch we send email only. We do not send text messages.
6.4 We do not sell your personal information.
7. Who we share information with
7.1 Installers
If you agree on the quote request form, we share your request and contact details with the installers shown to you. If one of them cannot respond, we automatically offer your request to another installer. Each request goes to a limited number of installers. Installers see a short summary of your request (job type, location and potential value) before they decide whether to accept it. They receive your contact details and the full details of your request only after accepting it.
Once an installer has accepted your request, it is a separate controller. It may use your details only to respond to your request and to deal with the job, and it must follow data protection law. Installers have their own privacy notices, which they must give you.
7.2 Our service providers (processors)
These companies handle information on our behalf and only on our instructions:
- hosting, database and file storage: Lovable Cloud. Lovable Cloud is built on Supabase, which hosts databases on Amazon Web Services. [TBD: the region where our database is stored];
- email delivery: Postmark;
- bot protection on forms: Cloudflare Turnstile;
- error monitoring: Sentry;
- analytics: Google Analytics 4, loaded through Google Tag Manager, only if you accept analytics cookies;
- postcode lookups: postcodes.io (only the postcode is sent);
- map display: OpenFreeMap, through the MapLibre map library. OpenFreeMap sees your IP address and the map area you view when the map loads. Its privacy policy says it sets no cookies, and that its normal access logs do not keep IP addresses (error logs that may include an IP address are deleted after 7 days). See https://openfreemap.org/privacy/.
7.3 Payments
Installers pay through Stripe. Stripe is a controller of some information for its own purposes, such as fraud prevention and legal compliance, and a processor for other information. See Stripe's privacy policy at https://stripe.com/gb/privacy.
7.4 Suppliers and affiliate partners
Some energy suppliers and charger brands pay us when you click a link on the site and then switch or buy (see our Terms of Use). We use an affiliate network, [AFFILIATE NETWORK NAME], for some of these links. When you click such a link, the supplier or the affiliate network can tell that you came from us, and may tell us that a switch or purchase happened, with a reference and the commission amount. We do not send them your name or contact details. On our side we record only which tariff link was clicked and whether it was a paid link. We do not record who clicked.
7.5 Others
We may share information with our professional advisers, with regulators, law enforcement or other public bodies where the law requires, and with a buyer if the business is sold, on the basis that your information is protected. We share information when we need to protect our rights or the safety of others.
8. Sending information outside the UK
8.1 Some of our providers are based in, or process information in, countries outside the UK, including the United States. UK law allows this when the destination has UK adequacy regulations, or an approved safeguard is in place.
8.2 For each such transfer we rely on one of:
- UK adequacy regulations, including the UK Extension to the EU-US Data Privacy Framework where the US provider is certified; or
- the UK International Data Transfer Agreement or the UK Addendum to the EU standard contractual clauses.
We choose the mechanism for each provider and check it before we start using that provider. If a provider's mechanism changes, we update this notice.
8.3 You can ask us for more details of the safeguards by emailing hello@evtariffscompared.com.
9. How long we keep your information
9.1 We keep personal information only as long as we need it for the reasons we collected it, and then delete or anonymise it. The table gives the periods we have set.
| Information | How long we keep it |
|---|---|
| Cookie and consent choices | 180 days, then we ask you again |
| Link to manage a quote request | 30 days |
| Newsletter confirmation link | 48 hours |
| Email sending logs | 90 days |
| Quote requests and the details you gave (including any photos you upload) | 12 months from the request, then deleted or anonymised |
| Record of your consent to share your details with installers | 6 years from the request, kept separately from the quote details, as evidence of your consent in case of a complaint or claim |
| Installer applications that are not approved | 12 months from the decision, then deleted |
| Installer accounts and lead history | For the life of the account and 6 years after it closes |
| Payment and invoice records | 6 years, to match legal record-keeping duties |
| Complaints | 3 years from the complaint being closed |
| Newsletter subscriptions | Until you unsubscribe. After that we keep your email address on a suppression list so that we do not email you again |
| Analytics data | 14 months (the retention period we set in Google Analytics 4) |
9.2 Installers who receive your request keep your details under their own retention periods.
9.3 We keep the record of your consent for 6 years because we may need to show that you agreed if there is a complaint, a claim or a regulator's question. The time limit for most claims in England and Wales is 6 years. The record is held apart from the details of your request, which we delete or anonymise after 12 months.
10. Your rights
10.1 You have the right to:
- be told how we use your information (this policy);
- ask for a copy of the information we hold about you;
- have inaccurate information corrected;
- ask us to delete your information in some situations;
- ask us to restrict how we use it in some situations;
- object to us using it, including where we rely on legitimate interests, and to direct marketing at any time;
- receive information you gave us in a portable format, where we use it based on consent or a contract and by automated means;
- withdraw your consent at any time, where we rely on it. This does not affect use before you withdrew.
10.2 To use a right, email hello@evtariffscompared.com. We may need to check who you are. We will respond within the time limit set by law and will tell you if we need more time. There is normally no charge.
10.3 If you ask us to stop using your details, we will pass the request to installers who have your details where we are able to, but you may also need to contact them directly.
11. Complaints
11.1 If you are unhappy with how we have handled your information, please tell us first at hello@evtariffscompared.com. Please say what has gone wrong and what you would like us to do. We will acknowledge your complaint, look into it without unnecessary delay and tell you the outcome. You can send your complaint by email, which works as a complaint form you can complete electronically.
11.2 You also have the right to complain to the ICO at https://ico.org.uk/make-a-complaint/. You can do so at any time, but the ICO usually expects you to raise the issue with us first.
12. Security
We use technical and organisational measures to protect personal information, including encrypted connections, access controls and limiting access to staff and providers who need it. No system is completely secure. If a breach affects your rights and freedoms, we will tell you and the ICO as the law requires.
13. Cookies and similar technologies
The site uses cookies and similar storage. Optional cookies (analytics and marketing) are off until you choose to accept them. See our Cookie Policy.
14. Changes to this policy
We may update this policy. We will put the new version on the site with a new date. If a change is important, we will tell you by email where we have your address.
15. Contact
EV Tariffs Compared
[COMPANY NAME], company number [COMPANY NUMBER]
Registered office: [REGISTERED ADDRESS]
Email: hello@evtariffscompared.com
ICO registration number: [ICO REGISTRATION NUMBER]
Contact us or email hello@evtariffscompared.com.