PRIVACY POLICY

Your rights, your information and how we use it

Active Energy Group Plc is committed to protecting your personal information.

Our Privacy Policy contains important information about what personal details we collect; what we do with that information; who we may share it with and why; and your choices and rights when it comes to the personal information you have given us.

We may need to make changes to our Privacy Policy; so please check our website for updates from time to time. If there are important changes such as changes to where your personal data will be processed we will contact you to let you know. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

This version of our Privacy Policy was last updated 5 March 2020.

Who we are

Active Energy Group Plc (“AEG plc”) is a London listed (AIM:AEG) renewable energy company focused on traditional and second generation biomass products that have the potential to revolutionise the traditional coal fired-power industry and developing an international forestry management business.

For the purposes of data protection legislation AEG plc is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this Privacy Policy).

How to contact us

If you have any questions about our Privacy Policy, including any requests to exercise your legal rights, or the information we collect or use about you, please contact:

27-28 Eastcastle Street, London W1W 8DH United Kingdom
Registered in England and Wales: Company No. 03148295

Email: [email protected]

Information we collect and use

Information about you that we collect and use includes:

Information about who you are e.g. your name and contact details
Information about your contact with us e.g. meetings, phone calls, emails / letters
Information that is automatically collected e.g. via cookies when you visit one of our websites
Information if you visit one of our offices e.g. visual images collected via closed circuit television (CCTV)
Information about your shareholding e.g. the number of shares you hold and the votes you cast

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide us with information

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time

Where we collect your information

We may collect your personal information directly from you, including:

Submission of an online form via our website
phone conversations with us
emails or letters you send to us
registering for one of our events

As you interact with our website, we will automatically collect information about your equipment, browsing actions and patterns. We collect this personal data by using cookies. Please see our cookie policy for further details.

We may also collect information about you via third parties or other sources e.g. our CCTV cameras.

What we collect and use your information for

We take your privacy seriously and we will only ever collect and use information which is personal to you where it is necessary, fair and lawful to do so. We will collect and use your information only where:

where we need to perform the contract we are about to enter into or have entered into with you
where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
you have given us your consent
it’s necessary for us to meet our legal or regulatory obligations

We collect and use your personal data for the following purposes:

to manage our relationship with you;
to compile and update our records;
to send you information you have requested;
to manage your rights as a shareholder;
to contact you with shareholder information and related communications;
to keep our premises secure;
to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data); and
to use data analytics to improve our website, products/services, marketing, customer relationships and experiences

We strive to provide you with choices regarding certain personal data uses, particularly around marketing. You can ask us to stop sending you marketing information at any time by contacting us. If you do not wish us to collect and use your personal information in these ways, it may mean that we will be unable to provide you with certain AEG Plc updates.

We sometimes use systems to make automated decisions based on personal information we have – or are allowed to collect and use from others – about you. These automated decisions can affect the information we share with you now or in the future. We use automated decisions in the following ways:

Tailoring information e.g. placing you in groups with similar individuals to make decisions about the information we may offer you to help meet your needs
When designing and enhancing our online services to help meet your requirements for ongoing guidance and support

Who we may share your information with

We will never sell your details to someone else. Whenever we share your personal information, we will do so in line with our obligations to keep your information safe and secure. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions

As an AIM Listed Company, we are under an obligation to notify the London Stock Exchange by way of a Regulatory Announcement as and when we are notified that a shareholder’s holding in AEG Plc reaches 3% of the total share capital and whenever there is an increase or decrease to such shareholding through any single percentage. Therefore, there may be times when it will be necessary to announce details of your name and/or holding to the general public.

Where your information is processed

The majority of your information is processed in the UK and European Economic Area (EEA).

However, some of your information may be processed by us or the third parties we work with outside of the EEA.

Where your information is being processed outside of the EEA, we take additional steps to ensure that your information is protected to at least an equivalent level as would be applied by UK / EEA data privacy laws.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or EEA.

How we protect your information

We take information and system security very seriously and we strive to comply with our obligations at all times. Any personal information which is collected, recorded or used in any way, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection obligations.

Your information is protected by controls designed to minimise loss or damage through accident, negligence or deliberate actions. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How long we keep your information

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. In some circumstances you can ask us to delete your data. Please see your individual rights below for further information.

Your individual rights

Circumstances depending, you have various rights in relation to how AEG plc uses your information. They are:

Right to be informed

You have a right to receive clear and easy to understand information on what personal information we have, why and who we share it with – we do this in our Privacy Policy and privacy notices.

Right of access

You have the right of access to your personal information. If you wish to receive a copy of the personal information we hold on you, you may make a data subject access request (DSAR).

Right to request that your personal information be rectified

If your personal information is inaccurate or incomplete you can request that it is corrected, though we may need to verify the accuracy of the new data you provide to us.

Right to request erasure

You can ask for your information to be deleted or removed if there is not a compelling reason for AEG plc to continue to have it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Right to restrict processing

You can ask that we block or suppress the processing of your personal information for certain reasons. This means that we are still permitted to keep your information – but only to ensure we don’t use it in the future for those reasons you have restricted.

Right to data portability

You can ask for a copy of your personal information for your own purposes to use across different services. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Right to object

You can object to AEG plc processing your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Rights to withdraw consent

You can withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

How to exercise your rights

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

How to make a complaint

We will always strive to collect, use and safeguard your personal information in line with data protection laws. If you do not believe we have handled your information as set out in our Privacy Policy you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so in the first instance please contact us via the Contact us page on the website, we will do our utmost to make things right.

Third party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.