Plico

Privacy Policy

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Last updated 4th July 2023

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

Our Privacy Statement explains how we collect, use and protect your information. It applies to all the businesses in the Plico Project including Starling Energy Group, CEPCO 2019, CEPCO 2022, Susi Partners and DCEP Inc. This Privacy Statement applies to the collection and use of personal information by the Plico Project, including information collected through the various websites operated by Starling Energy Group that link to this policy. It does not apply to personal information collected through websites that have their own Privacy Statements.

This Privacy Statement reflects how we manage and disclose your personal information while providing our services as organisations regulated under the Privacy Act. This Privacy Statement has no legal force and it does not create or impose any additional rights under the Privacy Act. It extends to both our control and processing of personal information. This current policy came into effect on 1 Jul 2023. We may need to update it over time but if we do, we will post the updated version on our website at www.plicoenergy.com.au/privacy-statement.

3 – The Plico Project entities

CEPCO 2019 Pty Ltd (ACN 634 959 845) and CEPCO 2022 Pty Ltd (ACN 664 797 102) are incorporated entities owned by the DCEP 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 and CEPCO 2022 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”.

Together they are referred to as “Plico Project”, “we” or “us” for the purposes of this policy.

4 – What is personal information?

Personal Information is any information or opinion about you that is capable, or reasonably capable, of identifying you, whether the information or opinion is true or not and is recorded in material form or not. Personal Information includes Sensitive Information.

Sensitive Information includes such things as your racial or ethnic origin, political opinions or membership of political associations, religious or philosophical beliefs, membership of a professional or trade association or trade union, sexual orientation or criminal record, that is also personal information. Your health, genetic and biometric information and biometric templates are also Sensitive Information.

We only collect Sensitive Information about you if we obtain prior consent to the collection of the information or if the collection is required or authorised by law.

5 – 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 our or our affiliates Service’s technologies.

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;
Financial and transactional information;
Username and password;
Comments and feedback;
Interests and communication preferences.

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 our website;
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 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.

6 – Consent

In most cases, before or at the time of collecting your Personal Information, we obtain your consent for the purposes for which we intend to use and disclose your Personal Information.

If you don’t give us consent, we may not be able to provide you with the products or services you want. This is because we are required to collect this Personal Information to provide you with the products or services.

7 – Withdrawing consent

Having provided consent, you are able to withdraw it at any time. To withdraw consent, please contact us. Please note that withdrawing your consent may lead to us no longer being able to provide you with the product or service you enjoy given that, as mentioned above, it is impracticable for us to treat some customers differently.

8 – 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.

9 – How do we deal with unsolicited Personal Information?

If we receive Personal Information that is not solicited by us, we only retain it, if we determine that it is reasonably necessary for one or more of our functions or activities and that you have consented to the information being collected or given the absence of your consent that it was impracticable or unreasonable for us to obtain it under the circumstances.

If these conditions are not met, we destroy or de-identify the information. If such unsolicited information is Sensitive Information, we obtain your consent to retain it regardless of what the circumstances are.

10 – 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 Project. We use the personal information collected through the VPPSA Service to complete various actions:

to proceed with Synergy and Western Power applications in relation to the potential installation of the Plico system; 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.
Identifying potential customers or subscribers.
to providing you with the services that you have subscribed to or registered for.
to deal with your requests and enquiries.
to carry out customer and marketing research and modelling
to provide you with information about products and services offered by the Plico Project.

We DO NOT sell personal information collected through this site or use your personal information for any other purposes than those stated above.

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.

11 – 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 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. We may share personal information with credit reporting body. The credit reporting body we deal with are Experian: www.experian.com.au.

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.

12 – 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.

We are committed to ensuring that we protect any Personal Information we hold from misuse, interference, loss, unauthorised access, modification and disclosure. For this purpose, we have a range of practices and policies in place to provide a robust security environment. We ensure the on-going adequacy of these measures by regularly reviewing them.

We have the following security measures in place to protect against misuse, loss and alteration of Personal Information under our control. Our security measures include, but are not limited to:

educating our staff as to their obligations with regard to your personal information;
requiring our staff to use passwords when accessing our systems;
encrypting data sent from your computer to our systems during Internet transactions and customer access codes transmitted across networks;
employing firewalls, intrusion detection systems and virus scanning tools to protect against unauthorised persons and viruses from entering our systems;
using dedicated secure networks or encryption when we transmit electronic data for purposes of outsourcing;
providing secure storage for physical records; and
employing physical and electronic means such as alarms, cameras and guards (as required) to protect against unauthorised access to buildings.

Where Personal Information we hold is identified as no longer needed for any purpose, we ensure it is effectively and securely destroyed, for example, by shredding or pulping in the case of paper records or by degaussing (demagnetise of the medium using alternating electric currents) and other means in the case of electronic records and equipment.

The Personal Information retained by us could include transactional and financial information along with contact details. The Personal Information does include the records that have been stored on the secure server. Where we retain adequate records for legal and accounting purposes, the Personal Information is stored and held securely in controlled facilities.

13 – 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.

Please contact us if any of the details you have provided to us change or if you believe that the information we have about you is not accurate or up to date. We may also take steps to update information we hold, for example, an address, by collecting Personal Information from publicly available sources such as telephone directories or electoral rolls.

14 – Do we use or disclose your Personal Information for direct marketing?

We only use or disclose the Personal information we hold about you for the purpose of direct marketing if we have received the Personal Information from you and you have not requested not to receive such information. Direct marketing includes, but is not limited to, contacting our clients to provide you with information on our products and services that may interest you.

If you wish to opt-out of receiving marketing information altogether, you can

email us: connect@plicoenergy.com.au
call us: 1300 175 426
write to us: Level 1, 191 St Georges Tce, Perth WA, 6000

In direct marketing communication we always inform you of your right to opt out of receiving direct marketing communications.

15 – 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.

16 – Can we refuse to give access?

In particular circumstances we are permitted by law to deny your request for access or limit the access we provide. We let you know why your request is denied or limited if this is the case. For example, we are not required to give you access where giving you access to your Personal Information would pose a serious threat to any person’s life, health or safety or giving access would be unlawful or where we reasonably conclude your request to be frivolous or vexatious.

If we refuse to give access to the Personal Information or to give access in the manner requested by you, we will give you a written notice setting out the reasons for the refusal, the mechanisms available to complain and any other relevant matter.

17 – 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.

email: connect@plicoenergy.com.au
phone: 1300 175 426
mail: Level 1, 191 St Georges Tce, Perth WA, 6000

If the matter is not resolved to your satisfaction, please contact our Compliance Officer in writing and send it to tzen.liong@plicoenergy.com.au or SEG, FLUX Level 6, 191 St Georges Terrace PERTH WA 6000.

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.

If you are not satisfied with our internal privacy practices or the outcome in respect to your complaint, you may approach the Office of the Australian Information Commissioner (“OAIC”) Commissioner with your complaint.

Office of the Australian Information Commissioner

Address: GPO Box 5218, Sydney NSW 2001

Phone: 1300 363 992

Email: enquiries@oaic.gov.au

Website: oaic.gov.au

AFCA is an external dispute resolution scheme in which we are a member. AFCA can consider certain privacy complaints relating to either the provision of credit or credit reporting information in general. You can lodge your complaint with:

Australian Financial Complaints Authority

Address: PO Box 3 Melbourne VIC 3001

Phone: 1800 931 678 (free call)

Email: info@afca.org.au

Website: www.afca.org.au

18 – Information collected on this website

Collection and use of information are through this website and Starling Energy Group website at www.plicoenergy.com.au and www.starling.energy. Other web sites by Starling Energy Group and other members of the Starling Energy Group are governed by their respective privacy statements.

We collect information from visitors (your visits) to this website through the submission of enquiry forms and every time you e-mail us your enquiry or details. Where that information is personal information, it is collected and handled in accordance with the general Privacy Statement set out above. In addition we log your IP address (this is the technical standard which ensures messages get from one host to another and that the messages are understood) which is automatically recognised by the web server.

19 – Notifiable data breaches scheme

From February 2018, the Privacy Act includes a new Notifiable Data Breaches (“NDB”) scheme which requires us to notify you and the Office of the Australian Information Commissioner (“OAIC”) of certain data breaches that is likely to result in serious harm to affected individuals and provide recommendations of steps you can take to limit the impacts of the breach.

If we believe there has been a data breach that impacts your Personal Information and creates a likely risk of serious harm, we notify you and the OAIC as soon as practicable and keep in close contact with you about the nature of the breach, the steps we are taking and what you can do to reduce the impacts to your privacy.

If you believe that any Personal Information we hold about you has been impacted by a data breach, you can contact us using the contact details set out above.

20 – Cookies

Cookies may be used by us to provide you with customised information from our web site. A cookie is an element of data that a website can send to your browser, which may then store it on your system. Cookies allow us to understand who has seen which pages and advertisements, to determine how frequently particular pages are visited and to determine the most popular areas of our web site.

Cookies may also allow us to make our website more user friendly by, for example, allowing us to save your password so that you do not have to re-enter it every time to visit our web site. We use cookies so that we can give you a better experience when you return to our web site. Most web browsers automatically accept cookies. You do not have to accept cookies, and you should read the information that came with your browser software to see how you can set up your browser to notify you when you receive a cookie, this will give you the opportunity to decide whether to accept it. If you disable cookies from your browser, you may not be able to access certain features of a particular website.

21 – 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.

22 – 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

email: connect@plicoenergy.com.au

phone: 1300 175 426

mail: Level 1, 191 St Georges Tce, Perth WA, 6000 or 3/18 Burler Drive Vasse WA 6280