Last updated 16th August 2019
1 – Our Privacy Commitment
Privacy matters to us and we know it matters to you. While information is the foundation for providing you with superior service, protecting the privacy of your personal information is of the highest importance to us. We believe that responsible stewardship of the information entrusted to us is crucial in developing and maintaining the public trust which in turn is essential for our continued success. We are sensitive to your privacy concerns and are committed to letting you know what kind of personal information is being collected and how the information is being used and disclosed
Our treatment of credit information is covered by our separate Credit Reporting Policy which lets you know how we use any credit related information we might collect
2 – Our Privacy Statement
3 – The Plico Energy Project entities
CEPCO 2019 Pty Ltd (ACN 634 959 845) is an incorporated entity owned by the DECP Inc Association, Susi Partners and Starling Energy Group.
DCEP Inc Association is Western Australian Association comprised of members
Susi Partners is a Switzerland-based fund manager, overseeing the investment in CEPCO 2019 through its investment entity Citadel HoldCo Pty Ltd (ACN 634 890 805)
Starling Energy Group (ACN 617 042 592) is a privately owned company based in Perth, Western Australia. For more information on the Starling Energy Group (SEG), please visit the company‘s website at Starling.Energy. Starling Energy Group owns the brand name “Plico Energy”.
Redback Operation Pty Ltd ACN 605 542 541 via the website located at http://redbacktech.com and Redback User Portal and Redback App
Together they are referred to as “Plico Energy Project”, “we” or “us” for the purposes of this policy.
4 – What kind of personal information do we collect?
The kind of information we collect depends on the purpose for which it is collected. In relation to our employees we may collect name and home contact details such as addresses, phone numbers and email addresses. We may also collect details of their next of kin for emergency contact purposes.
The core VPPSA service collects information from you in two ways: directly from your input and automatically through the Service’s technologies
4.1 – Information provided by you
The types of information the Service collects directly from you may include the following as well as any other information type that we expressly ask you to enter and submit to the Service:
Contact information, such as your name, email address, postal address and telephone number;
Username and password;
Comments and feedback;
Interests and communication preferences.
4.2 – Information Collected Automatically
The Service automatically collects certain information regarding your use of the Service. Example of information collected automatically include:
Internet Protocol (“IP”) address used to connect your computer to the internet;
Computer, device and connection information, such as browser type and version, operating system, mobile platform and unique device identifier (“UDID”) and other technical identifiers;
Uniform Resource Locator (“URL”) click stream data, including date and time, and content you viewed on a Service;
Location information for location-aware Services to provide you with more relevant content for where you are in the world;
Operation and system performance data of Hardware products connected to our Service (this includes running state of individual components, battery temperature, communication status, uptime);
Information about your energy use and other electrical data, including usage, production, state of charge of the battery and appliance use;
Service use, including portal and application use.
We may use and disclose automatically collected information for any purpose, except where we are restricted by applicable law. If we combine any automatically collected information with personal information, the combined information will be treated by us as personal information. We may also use aggregated information for any reasonable and necessary purpose, however, this information does not identify specific individuals and so is not personal information.
A significant part of our business is in the collection and analysis of data and the development of value added services and as part of that we may obtain data which includes utility bills, interval energy data and relevant household electrical information to assist the Plico Project to analyse and deliver its Virtual Power Plant Services under the VPPSA.
The Plico Energy Project and its service providers use technologies (like cookies and web beacons), for various purposes, including: facilitating the login process, administering, customizing and improving the Service, personalizing the browsing experience, advertising, promotions, surveys, reporting and third party holders, such as your electricity providers, as well as tracking and analysing user preferences and trends.
5 – How do we collect personal information?
Wherever reasonably possible, we collect personal information from the person or device to whom it relates. For example, you may provide your name, phone number and address to allow us to understand you house requirements and communicate with you. As part of our assessment we also collect and use personal information from publicly available sources and from third parties such as councils, aerial photograph suppliers and energy utilities. However, we only do so if the individual has consented to such collection or would reasonably expect us to collect their personal information in this way, or if it is necessary for specific purpose such as the investigation of a privacy complaint. Where we collect personal information from third parties we are careful to seek confirmation from those providing us with the information that it was acquired in accordance with the requirements of the Privacy Act, that they are entitled to provide it to us and that they can authorise us to use it for the purposes for which they are supplying it. Similarly, if you have provided us with your contact details, and those details subsequently change, we would appreciate your informing us of the change so that we can ensure our records are kept up to date.
6 – Why do we collect personal information and how do we use it?
We are in the business of providing our customers with analytical, energy insight and Energy VPP services to help them improve the value of their VPPSA contract. To do so we gather, analyse and process large volumes of information, some of which is personal information, including data sourced from various third party sources and other members of the Plico Energy Project. We use the personal information collected through the VPPSA Service to complete various actions:
to provide, improve and develop the VPPSA Service;
to provide support to VPPSA Members;
to respond to requests, inquiries, complaints or applications;
to update you on relevant new services and benefits;
to personalize the Service and to select content to be communicated to you or to use features on the Service;
to contact you regarding our products or services or other products and services from third parties;
to conduct website administration, such as technical support of our websites and computer systems;
for data analysis, audits, developing new products, enhancing the Service, identifying usage trends and determining the effectiveness of our promotional campaigns, or in other ways to which you have expressly agreed in a customer agreement with us;
to prevent and detect security threats, fraud or other malicious activity; and
to comply with our legal obligations, resolve disputes, and enforce agreements.
We may collect, hold, use and disclose your personal information for other purposes which are within reasonable expectations or where permitted by law. We may on occasion also match and combine the personal information that you provide with information that we obtain from other sources or that is already in our records, whether collected online or offline or by predecessor or affiliated group companies, for the purposes described above.
7 – Who do we disclose personal information to?
We share your personal information in the following ways:
Your personal information may be accessible to all Plico Energy Project affiliated companies worldwide for the purposes described in this policy.
Service Providers. Your personal information may be accessible to our service providers and suppliers, which assist us with producing and delivering our products and services, operating our business and marketing, promotion and communications. These providers and suppliers include, for example, bill processing, installers and shipping agents.
Sponsors, Business or Joint Venture partners. Your personal information may be accessible to our agents, representatives, sponsors and other entities for which we are acting as a joint venture or business partner.
Other Third Parties: We may share personal information with other third parties if we expressly told you about such potential disclosure at the point at which you submitted the Information to us.
Compliance with Law and Similar Obligations. We may share personal information in order to: (i) respond to or comply with any law, regulation, subpoena or court order; (ii) investigate and help prevent security threats, fraud or other malicious activity; (iii) enforce and protect the rights and properties of Starling Energy Group or its affiliates; or (iv) protect the rights or personal safety of our employees and third parties on or using our property.
Change in Corporate Circumstances. If Starling Energy Group, the Service or related asset or line of business is acquired by, transferred to or merged with another company, your personal information may be disclosed to the prospective and actual purchasers.
We work towards ensuring that the information we disclose is used only in accordance with this policy and in accordance with the requirement of the Privacy Act. Under certain circumstances Starling Energy Group may disclose your personal information if it is required by or under an Australian law or a court / tribunal order or we reasonably believe that the use or disclosure of the information is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of an enforcement body.
8 – How secure is your personal information?
As a global leader in the management of data, the Starling Energy Group recognises and acknowledges the importance of keeping the personal information and data that it holds, secure and protected from unauthorised access. To do this, at a minimum, Starling Energy Group utilises industry standard security, encryption processes and technology and we ensure that access to your personal information is only provided to those employees who need to have access to perform their role. Access is also provided to users and subscribers of the products and services we offer and any law enforcement agency with whom we are required by law to provide your personal information. These standards operate globally across the Starling Energy Group and so, if we disclose your personal information to any of our overseas affiliates, the same level of security will apply. To the extent that we disclose any personal information to our clients or partners, we require that they implement appropriate safeguards with regard to the security of that information. We may be obliged to disclose personal information we hold to law enforcement agencies. In such circumstances the use and security of that information is determined by the rules governing the relevant agency. To ensure that we maintain the standards we have set for security and that we comply with our obligations in relation to the storage and handling of your personal information Starling Energy Group requires all of its employees to complete regular training and an annual certification in relation to the handling of personal information and the application of our security policies. We will also regularly review this policy and assess our performance against it to ensure we are meeting and continue to meet our obligations under the Privacy Act.
9 – How do we maintain the quality of your personal information?
It is extremely important to us that the personal information we hold about you is up to date and accurate. The information we receive from the users of our products and services and the data we collect from publicly available sources and 3rd parties are subject to various processes to ensure the information is accurate. Where updated information is available we will incorporate it into our products as soon as practicable. The time it takes to apply updates to products depends on the product itself and the sources of data relevant to it. Whilst some information can be updated almost immediately; others have release cycles as long as three months, so the time taken for a change to become effective may vary considerably.
10 – How can you access or correct the personal information we hold?
Should you wish to gain access to or correction of your personal information, you may contact us at Starling Energy Group. Generally, we are happy to provide details of the information we hold free of charge. However, to the extent permissible under law, we reserve the right to charge a nominal fee commensurate with our costs of extraction and collation of information where significant work is involved. We will require you to adequately identify yourself when requesting a copy of your personal information. If you would like us to update your information or you believe that any of the information we hold is incorrect, please let us know. Where we have obtained information directly from you, we may occasionally ask you to update your information. Data will not be kept for longer than is necessary and will be removed from our database at your request. If you wish Starling Energy Group to delete your profile, you may contact us at Starling Energy Group. There are certain limited circumstances permitted under the Privacy Act in which we may decline to permit you access to the information we hold, or we may decline to apply a correction to that information which you have requested. In such circumstances, you may require that we note that a request for access or correction has been refused by us
11 – How can you complain about our use of personal information?
Where you feel the information we have provided to you may not be accurate or you have a dispute regarding the information we hold, you may contact us at Starling Energy Group in order for us to investigate the matter further. In general we aim to respond to all complaints promptly and in any event in less than 30 days. We aim to act promptly and reasonably in resolving any complaints. There are some circumstances, for example, where the matter is complex, or the resolution relates to a product with a long update cycle, where we may require additional time to resolve an issue or to implement a correction. Upon conclusion of our investigation if you are not satisfied with the outcome of our investigation, you may escalate the matter to the Office of the Australian Information Commissioner or our external dispute resolution scheme using the details below. Contact details for both parties are as follows: Office of the Australian Information Commissioner GPO Box 5218 SYDNEY NSW 2001 Website: www.oaic.gov.au Collection and use of information through this website This section only covers Starling Energy Group’s web site at www.experian.com.au. Other web sites by Starling Energy Group and other members of the Starling Energy Group are governed by their respective privacy statements.
12 – Information collected on this website
13 – Use of personal information
We process personal information collected via this web site for the purposes of:
Identifying potential customers or subscribers
Providing you with the services that you have subscribed to or registered for
Dealing with your requests and enquiries
Carrying out customer and marketing research and modelling
Providing you with information about products and services offered by the Plico Energy Project
We DO NOT sell personal information collected through this site or use your personal information for any other purposes than those stated above.
14 – Cookies
15 – Internet-based transfers
Given that the Internet is a global environment, using the Internet to collect and process personal data necessarily involves the transmission of data, sometimes on an international basis. Therefore, by browsing this website and communicating electronically with us, you acknowledge and agree to our processing of personal data in this way.
16 – Updating information
Where you have provided us with information through this website, you may access and update your data at any time by contacting us.
C/O Starling Energy Group
Level 1, 191 St Georges Tce
Perth WA 6000
Ph: (08) 6115 6320