CUSTOMER PRIVACY NOTICE
AvantiGas is committed to your privacy and the protection of your personal data. AvantiGas is a subsidiary affiliate of UGI International. UGI International’s European Economic Area (“EEA”), UK affiliates, including AvantiGas, are collectively referred to in this Privacy Notice as “UGI” or “we”, “our”, or “us”. We collect and process your Personal Data that is provided by you, as our customer, previous customer or prospective customer, or generated by you in your use of our services and purchase of our products. This Privacy Notice is provided to you in accordance with applicable privacy laws including, but not limited to the Data Protection Act 2018 and any applicable national legislation implementing the latter (together the “Data Privacy Laws”).
Data Controller
AvantiGas is the data controller under applicable Data Privacy Laws in relation to your Personal Data. A Data Controller determines the purposes and means of processing your Personal Data and implements appropriate technical and organizational measures to ensure that the processing is undertaken in compliance with applicable law. Avanti Gas Ltd is a company registered in the United Kingdom under registration number 00481121 with the registered address at UGI House, Gisborne Close, Chesterfield, England, S43 3 JT.
Your Personal Data
Your Personal Data includes any information relating to you where you are identified or from which you are identifiable. We may collect and process the following Personal Data relating to you:
- your family and first names;
- your postal and email addresses;
- your delivery address and GPS coordinates;
- your date and place of birth;
- your land and/or cell/mobile phone numbers;
- your customer code;
- identifiers; and/or
- your bank or credit card details.
We collect various types of Personal Data from different sources, including:
- account information you provide to us when you open and modify your account;
- information you provide directly to us when you register to use our website;
- information you provide to us to obtain services or products provided by us;
- information we collect about your use of our services, purchase of our products and provided by you in emails or telephone calls to us or from third parties authorized by us; and
- information we collect to process payments by telephone or online.
Some of the Personal Data you provide to us may include health information or other sensitive or special categories of Personal Data. If you provide this information to us we will only use it if relevant to your engagement with us (e.g. in our communications with you, or as needed to provide the services or respond to your inquiry or request).
In addition, we may combine your Personal Data collected at the time the energy supply contract between you and AvantiGas (“Contract”) is signed with other Personal Data that we or third parties legally collect about you such as in particular our communications by email, telephone or otherwise or recordings made during our telephone communications. Where we record calls (to the extent authorized by applicable law and as notified to you at the start of such recorded calls), these calls will contain your Personal Data and we retain the recordings of those calls in accordance with our retention periods (see below in this Notice). All your Personal Data collected directly or indirectly, will be processed and protected in accordance with this Privacy Notice.
We collect some Personal Data with your consent, as follows:
- Marketing purposes, subscription to receive our commercial or promotional information, home visits, your participation or enrollment to a fair or event;
- Your use of our websites, notably when creating or managing your client account
- Your ability to make payments, by telephone or online
- Our communications, in particular with client service or delivery service;
- Monitoring the quality of our service, notably recordings of our telephone conversations;
- Managing our loyalty programs;
- Recording your statements of deposit of our LPG cylinders/tanks;
- Participation in competitions, contests or surveys; and/or
- Undertaking surveys by specialized service providers.
We do not request and, so far as we are aware, collect Personal Data regarding minors under the age of 16.
Why do we collect your Personal Data?
We collect and process your Personal Data to conduct our business in order to ensure you receive quality services. We only collect Personal Data that is adequate, pertinent and limited to what is necessary in light of the purposes for which it is processed.
One of the legal basis for collecting and processing your Personal Data is to carry out all pre-contractual and contractual steps and perform the Contract. We also collect your Personal Data in order to comply with our legal, regulatory and contractual obligations, and also to defend and establish our interests, in particular legal claims and other disputes with customers and/or with third parties.
For the purposes of this Notice pre-contractual steps mean any action undertaken by us during the presentation of our service and product offerings that may require collecting Personal Data in order to meet your expectations.
Providing Personal Data is necessary to enter into and perform the Contract. If your Personal Data is not provided, we will not be able to satisfy your requests or provide you with the requested products and services.
More specifically, we use your Personal Data for the following reasons:
- Perform our obligations to provide products and services and set forth in the Contract;
- Enable payment processing transactions;
- Offer you services that meet your needs;
- Comply with our legal and regulatory obligations and requirements;
- Sending you commercial and advertising information, based on your preferences and with your consent;
- Manage any technical issues or support requests that may arise; and
- Perform our obligations to you.
We also process your Personal Data to fulfil our legitimate interests of:
- Managing any litigation with you or with a third party in which your Personal Data is involved;
- Developing effective and innovative products;
- Undertaking analyses and developing statistics to adapt our commercial and logistical activities;
- Facilitating order fulfillment, including route planning and demand forecasts; and
- Utilizing customer segmentation to support the development of more tailored communications, service and/or offers to customers.
What we do with your Personal Data
Your Personal Data may be shared with the following recipients, if sharing is necessary to achieve the purpose of the collection and processing of your Personal Data:
- Internal recipients: our client service centers and logistics offices; our financial, legal and marketing departments; the marketing departments of our subsidiaries; and the legal and internal control functions of our affiliates, including our parent company, that may be in third countries which are bound to comply with applicable data privacy requirements.
- Third party recipients engaged by us to fulfill the Contract or to enable us to provide the services and products to our customers, our external advisors and auditors, our counterparties (where relevant) and service providers engaged by us; Third party recipients include: transporters; inspectors and persons responsible for maintenance of technical installations; call centers; event organizers, public relations, advertising and marketing agencies; partner platforms; lead generators; printers, document management and hardcopy or online archiving providers; studies or statistical analysis providers; providers of third party application maintenance, software services and storage; banks; and, in the event of a dispute, investigators, legal advisors, collection agencies, court bailiffs, attorneys and notaries and parties to the dispute.
We may disclose your Personal Data to our subcontractors, agents, or payment service providers that we contract with to assist us in providing the services.
There may be instances when we disclose your Personal Data to other parties in order to: (i) comply with the law or respond to compulsory legal process (such as a search warrant or court order) or request for information from a regulator or otherwise for legal purposes; (ii) verify or enforce compliance with the policies governing the services; or (iii) protect the rights, property or safety of us, or any of our affiliates, business partners, or customers or otherwise in our and/or our affiliates’ legitimate business interests and in accordance with Data Privacy Laws.
We may share your Personal Data with other business entities in connection with the sale, assignment, merger or other transfer of all or a portion of our business to that business entity.
In any instance where we need to share your Personal Data with third parties, we will restrict the nature and categories of Personal Data to that which is required to comply with our contractual obligations to you or our legal and/or regulatory requirements. We may de-identify your Personal Data to protect your privacy.
International transfer of Personal Data
Due to the multinational character of the UGI Group, some of the affiliated companies and other recipients listed above may be located in countries (including the United States) that do not provide a level of data protection equivalent to that set forth by the law in your home country. When we transfer Personal Data to recipients which are located outside the European Union, the European Economic Area, or the United Kingdom, we will provide an adequate level of protection of your Personal Data, including appropriate technical and organizational security measures and through the implementation of appropriate contractual measures to secure such transfer, in compliance with applicable law.
We mainly use standard contractual clauses in the form approved by the European Commission but may also rely on adequacy decisions, Binding Corporate Rules, or any future mechanism approved by the European Commission.
A copy of the relevant contracts or evidence of any other mechanism used can be made available to you upon request.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
How long we keep the Personal Data
We retain your Personal Data relating to the use of our services for the duration of the customer relationship plus the time necessary to comply with any applicable legal, regulatory, audit and tax requirements. After this period has expired, the Personal Data relating to your account and your use of the services will be deleted or anonymized in accordance with Data Privacy Laws. Any Personal Data which you have provided to us for marketing purposes will not be kept for longer than 2 years or after you notify us that you no longer wish to receive this information.
Changes to our privacy policy
This Privacy Notice may be reviewed and updated from time to time. Should we materially change our Personal Data practices or this Notice, we will issue a revised Notice and/or take other steps to notify you of the changes in accordance with Data Privacy Laws.
This privacy policy was last updated on 10/08/2023
What are your rights?
You have a number of rights relating to your Personal Data. Subject to certain conditions in accordance with the Data Privacy Laws, you may request:
- access to your Personal Data;
- rectification of your existing Personal Data;
- erasure of your Personal Data, subject to other regulatory or contractual obligations;
- porting of your Personal Data (the right to portability allows you to obtain some of your data in an open, machine-readable format) where the data is processed on the ground of consent and by automated means;
- objection to processing your Personal Data; or (
- restriction of processing your Personal Data in order to verify its accuracy, object to its erasure or exercise or defend your legal rights.
You also have the right to raise concerns to your local supervisory authority about our processing of your Personal Data.
To exercise any of these rights, if you have any questions about this Privacy Notice or about our handling of your Personal Data or if you wish to raise a complaint on how we handle your Personal Data, you can contact our Data Protection Officer by sending an email to privacy@ugiintl.com.