Who we are and this privacy notice
Sunamp is a pioneer of innovative thermal storage solutions. We are subject to differing data protection regimes in the jurisdictions in which we operate. This notice reflects our obligations to inform you about the types of personal data we process about you and what we do with your data. In countries where data protection regimes differ significantly, elements of this notice may not apply, for example individuals’ rights in relation to personal data.
This notice applies to all Sunamp group companies. For some jurisdictions, separate privacy notices apply.
For the UK: https://sunamp.com/en-gb/privacy/
For Italy: https://sunamp.com/it/privacy-policy/
For USA: https://sunamp.com/en-us/privacy-policy-usa/
For Canada (in English): https://sunamp.com/en-ca/privacy-policy-canada-english/
(French) https://sunamp.com/en-ca/politique-sur-la-protection-canada-francais/
For Australia: https://sunamp.com/en-au/privacy-policy-australia/
How to contact us
We want to offer you a means of contacting the right people in our organisation as easily as possible. If you have any questions about your personal data or our privacy notices, please contact us on the details below. You are welcome to contact any of our offices directly.
Contact details of our Data Protection Officer
Sunamp Data Protection Officer
Sunamp Ltd, 1 Satellite Park, East Lothian, EH33 IRY
Email: [email protected]
Cookies
If you are using our website, please see our Cookies Policy for information about what cookies we use on our website and how you can change your cookie preferences.
The types of information we process about you
We may collect, use, store and transfer different kinds of personal data about you depending on the nature of our relationship with you, which we have grouped together as follows:
- basic personal data about you and your contact details including name, address, email, telephone number, country, zip code/postcode so we can contact you.
- bank and financial information if we are setting up a contract with you or conducting a credit worthiness evaluation.
- product information, test results, evaluations, questionnaire answers, water metering and usage and utility billing information so we can provide support if you or your supplier contacts us in relation to a product enquiry or warranty or you are part of a trial or case study to test and evaluate our products and services.
- your face and voice if you consent to be part of Sunamp training, promotions and marketing in the media.
- information from job applicants and to monitor our recruitment (which may include sensitive personal data). If you are applying for a role at Sunamp please read our Job Applicant Privacy Notice for more details.
Sensitive or special categories of personal data
The definitions of sensitive or special categories of personal data varies between different jurisdictions. In some specific circumstances we may process such personal data about you, in which case we take particular care to only process such data in accordance with the strict legal parameters. Sensitive or special categories of personal data can include information about your health, race, ethnic and communal origin, religious, philosophical or political beliefs, trade union membership, sex life or sexual orientation, or genetic or biometric data. Please read our Job Applicant Privacy Notice for details about when and why we may process personal data relating to criminal convictions and offences.
Where your data comes from and why we collect and use your data
You may provide us with your personal data when you contact us, use our website or interact with us in person or virtually (at an event, meeting, training, conference or exhibition) or on social media. We will contact you based on the consent you give us at the time we meet or interact. We may receive personal data from our partners and distributors where you purchase our products from them or as part of third party hosted events. This may be to support you or them with service issues or to respond to warranty claims or general enquiries. We may also receive information about you where you have participated in field trials or case studies or as part of training we and our partners offer.
By completing the contact form on our website you are confirming you would like to receive information from us.
We always seek to minimise the information we ask for to what is needed to perform the relevant function or service at the time. We will not collect any personal data from you that we do not need to provide and oversee our services and marketing to you.
We process your personal data so we can:
- manage your relationship with us (for example, respond to your enquiries, deal with questions about our products and services, respond to sales, customer service matters)
- manage product warranty claims. If you purchased a Sunamp product which included a warranty from us, we will need your contact details so we can support you under that warranty. If you don’t complete and return the warranty information, we may not be able to help you
- manage and operate the product trials we conduct, support installations, work with suppliers and resellers
- provide training, webinars and information sessions. If we propose to record an event or training you will see or hear a notification. Our purpose for recording a training session or event will be to enable us to share a session with further participants or provide a copy to attendees. We will only do this where appropriate, considering our data protection and confidentiality obligations.
- manage our marketing and promotional campaigns. We would like to use your name and email address to inform you of our future offers and products and to keep you informed with our regular newsletter and company updates. This information is not shared with third parties unless you give us your informed consent to share the information with them and you can unsubscribe at any time via email.
- if you give us your consent, use your personal information including your face, voice, images of where you work and live where Sunamp products and systems are installed, as part of Sunamp training, media and marketing campaigns. In countries where express consent is required for the assignment of image rights, we will provide you with the relevant authorisation to complete. Where you do not provide such authorisation, your image and/or voice will not be used for any marketing-related activities.
Please note that you have the right to withdraw your consent. You can do this by contacting [email protected] or using the unsubscribe on marketing messages we send you.
For customers in the UK and Italy: Use of your personal data for targeted advertising
If you have agreed to receive direct marketing from us by email, we will use social media and digital advertising platforms to provide you with targeted advertising. The legal basis we are relying on to do this, is your consent.
To do this, we securely transfer your name and email address to social media platforms Facebook, Instagram, LinkedIn and X (Twitter), or Google’s digital advertising platform. This data is then compared with the data held by the social media or digital advertising platform. If the data matches, this means that you are also active on the third party’s platform.
You may be included in a target audience which is created using the matched customer data. This allows us to deliver targeted advertising (called ‘customer match’ advertising), increasing the relevance of the ads you are shown on social media or digital advertising platforms, based on the information we have about you.
We may also use this information to identify other users like you, who might be interested in our products or services, and to deliver targeted advertising to these users (this is called a ‘lookalike audience’).
You can withdraw your consent at any time with effect for the future. You can opt out of marketing from Sunamp by following the unsubscribe process in our marketing emails or notifying us directly by sending an email to [email protected].
You can opt out of receiving targeted advertising on your social media accounts by adjusting your settings on each social media platform. You’ll find instructions on each platform’s website and can see more details in their privacy notices.
Compliance with data protection regulations
We will only use your personal data when the law allows us to. What is allowed depends on the relevant circumstances and jurisdiction. When we process your personal data it will be on the basis of one or more of the following:
- You have given us your consent. For example, this could be in relation to receiving marketing or being part of Sunamp marketing including on social media, participating in training or product trials, or as part of a job application.
- Where we are required to complete or perform a contract with you.
- In certain circumstances, where we have a legitimate interest to do so. This is where the processing of your personal data is necessary to pursue our legitimate interests in a way which is reasonably expected as part of running our business, but which is not detrimental to you and would have minimal impact on your privacy. We undertake an assessment of any potential impact on your privacy before we process your personal data for our legitimate interests.
- We need to verify the accuracy of the data we hold about you, to conduct research and field trials, to comply with the terms of a product warranty, to comply with our obligations for grants and investments and where we need to manage queries, complaints.
- We need to investigate, commence or defend legal claims and proceedings.
- You have given us your consent to pass your contact details to a commercial partner, supplier, installer who may be able to help you directly with your enquiry.
- To comply with our legal obligations (for example laws related to anti-money laundering, sanctions and anti-corruption).
Sharing your personal data and security
All the personal data we hold is processed by our personnel in the UK, Switzerland, Italy, USA and China. Where data is transferred between members of Sunamp this is conducted strictly in accordance with applicable data protection law. We share your personal data only where necessary within our group of companies, with our approved partners, contractors and suppliers (including third parties who provide our IT services), our legal and professional advisors, banks, insurers, government and regulatory authorities. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We may need to transfer and use your personal data outside of the country where we collect it from you. We implement appropriate measures to protect your personal data when we transfer your personal data outside of your home country such as data transfer agreements that incorporate standard data protection clauses. The data privacy laws in the countries we transfer it to may not be the same as the laws in your home country. Law enforcement agencies, regulatory agencies, security authorities or courts in the countries we transfer your personal data to may have the right to see your personal data.
For the purposes of IT hosting and maintenance, information is located on servers in the UK, EU, USA and Asia. No third parties have access to your personal data unless the law or our contract with you or the consent you have provided us, allows them to do so.
We have a data protection regime in place to oversee the effective and secure processing of your personal data.
Additional information if you are based in the European Economic Area (also see the separate section below on processing personal data in the European Economic Area)
The European Commission recognises that some countries outside the European Economic Area have similar data protection standards. However, if we transfer your personal information to a country that is not considered to have similar data protection standards, we do so in compliance with the EU General Data Protection Regulation and in accordance with this notice.
How long we keep your data
We keep your data in accordance with our regulatory obligations for the length of time agreed on, or only for so long as we need it to provide support to you, after which time it will be deleted. If you have consented to receiving marketing communications from us, the information we use for marketing will be kept until you notify us that you no longer wish to receive this information.
If you would like more details or have questions on our retention policies, please contact [email protected].
What are your rights?
You have rights under data protection laws in relation to your personal data including the right to be informed about the collection and use of your personal data. The data protection laws in the country in which you reside may entitle you to specific rights in relation to your personal data and this notice does not take away those rights nor establish rights or obligations which are additional to those prescribed in the applicable local data protection law.
For example, the following rights are provided for under the UK and EU data protection regimes:
- to be informed about the collection and use of your personal data;
- to ask whether we process your personal data and request a copy of it if so;
- to object to decisions that we may make based solely on the automated processing of your personal data;
- in certain circumstances, to object to processing of your personal data where we do so for the purposes of our legitimate interests;
- to request that any inaccurate or incomplete personal data of yours in our care is rectified or competed;
- in certain circumstances, to restrict our processing of your personal data;
- in certain circumstances, to receive your personal data or have your personal data transmitted to another organisation in a structured, commonly used and machine readable format;
- in certain circumstances, to request that we delete your personal data; and
- to object to our processing of your personal data for direct marketing purposes.
Not all these rights are absolute, which means that they may only apply in certain situations and may be subject to legal exceptions and exemptions. They may also not apply in the country in which you reside. To exercise your rights, please email us at [email protected].
You can object to us using your personal information for direct marketing purposes at any time and we will automatically comply with your request. If you would like to do so, please email or write to us.
The accuracy of your information is important. If you change your name, address or email address, or you discover that any other information we hold about you is inaccurate or out of date, please contact us.
Contacting us and additional information for some countries
If you wish to raise a complaint on how we have handled your personal data, you can contact [email protected] and we will investigate the matter.
In some jurisdictions you have the right to make a complaint to a data protection supervisory authority, usually in the country or state where you work, normally live or where any alleged infringement of data protection laws has occurred.
Where your personal data is processed by an establishment located in the European Economic Area
Sunamp Limited is the data controller responsible for processing your personal data.
In the European Economic Area the EU General Data Protection Regulation requires us to inform you of the legal basis for the processing of your personal data.
The legal basis for our processing personal data about you is that such processing is necessary for the purposes of:
- exercising our rights and performing our obligations under any contract we make with you (Article 6 (1) (b) General Data Protection Regulation) (Contract Performance)
- compliance with our legal obligations (Article 6 (1) (c) General Data Protection Regulation) (Compliance with Legal Obligations)
- Legitimate interests pursued by us (Article 6 (1) (f) General Data Protection Regulation) (Legitimate Interest). Generally, the legitimate interest pursued by us in relation to our use of your personal data is the efficient performance or management of our business relationship with you or where we need to commence or defend legal proceedings; or
- if we have your consent (Article 6 (1) (a) General Data Protection Regulation) (Consent).
In the event that we transfer your personal data outside the European Economic Area, we ensure that your data is protected in a manner which is consistent with the EU General Data Protection Regulation.
The EU General Data Protection Regulation gives you the right to lodge a complaint with a data protection supervisory authority. Details of EU and European Economic Area countries data protection authorities can be found here:
https://www.edpb.europa.eu/about-edpb/about-edpb/members_en
If Swiss data protection law applies to the processing of your personal data the following additional information is relevant
Sunamp Switzerland GmbH and Sunamp Limited are the data controllers responsible for processing your personal data. Sunamp Limited is the Data Protection Representative pursuant to Article 14 of the Swiss Federal Data Protection Act. You can contact us on the details set out at the start of the notice.
You can contact us to request access to, update, remove and restrict the processing of your personal data. You also have the right to object to the processing of your information or export your information to another party.
We may transfer your personal information to a third country based on an exception provided for by the Swiss Federal Data Protection Act. An exception may apply in the event of:
- legal proceedings abroad,
- in cases of overriding public interest or if the performance of a contract with you or in your interest requires disclosure
- if you have consented
- if the information has been made generally available by you and you have not objected to the processing, or
- the disclosure is necessary in order to protect the life or the physical integrity of you or a third party and we can’t get consent within a reasonable period of time, or
- the information originates from a register provided for by Swiss law which is accessible to the public or to persons with a legitimate interest, provided that the legal conditions for the consultation of such register has been met in the specific case.
You have the right to enforce your data protection rights in court or to lodge a complaint with the competent data protection authority. The competent data protection authority of Switzerland is the Federal Data Protection and Information Commissioner.
Where your personal data is processed by personnel located in the People’s Republic of China or you reside in China the following additional information is relevant
Sensitive personal information means personal information that, once leaked or illegally used, may easily cause harm to the dignity of natural persons grave harm to personal or property security, including information on biometric characteristics, religious beliefs, specially-designated status, medical health, financial accounts, individual location tracking, etc. as well as the personal information of minors under the age of 14.
We will not process your sensitive personal information. In case your sensitive personal information will be processed, we will notify you about the necessity of processing and effects on the individual’s rights and interests, and obtain your specific consent if applicable.
In accordance with Article 23 of the Personal Information Protection Law of the People’s Republic of China, will not transfer or share your personal information to third party controllers, unless (1) we obtain your specific consent if applicable, or (2) to fulfil the statutory duties under local laws and regulations.
In the event of any reorganization (including the establishment of new, locally incorporated entities in China and the transfer of existing businesses in China to such new locally incorporated entities), merger, sale, liquidation, joint venture, assignment, transfer or other disposition of all or part of our business (including in connection with any bankruptcy or similar proceedings) involving the transfer of personal data, we will ask the new company or organization holding your personal data to continue to process your personal data in accordance with this notice. If the new company or organization holding your personal data needs to use your personal data for purposes not stated in this notice, the new company or organization will obtain your consent, unless otherwise provided by the applicable laws and regulations.
Where your personal data is transferred outside of the People’s Republic of China. We will follow the applicable laws and decisions imposed by the competent authority and ensure that your personal data is protected in a manner which is consistent with the Personal Information Protection Law.
We are required to inform you that the legal basis for the processing of your personal data is:
- Article 13(1) (Consent)
- Article 13(2) (Contract Performance)
- Article 13(3) (Statutory duties and responsibilities)
- Article 13(6) (Processing publicly available data)
Our products and services are not directed at children. We will not knowingly collect personal data from children under the age of 14 without prior parental consent if required by applicable law. We will only use or disclose personal data about a child to the extent permitted by law, to seek parental consent, pursuant to local law and regulations or to protect a child.
Changes to the Sunamp global privacy notice
To ensure we reflect what we do with your personal data or any change to our legal obligations, we will review and may change this notice from time to time. Any changes we make will be posted on our website and, if appropriate and possible, notified to you. Please check back frequently to see any updates or changes.
Updated: 27 February 2025
