Under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, you have the right to access the personal data we hold about you.
1. Data Collected and Processed
We process personal data in connection with your use of the Homely Hub, which monitors and supports your heat pump energy system, including through a mobile app and associated account. The categories of personal data we process include:
- Account Information: Name, email address, contact details, and user account credentials.
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Energy Usage Data: Data collected by the Homely Hub regarding your heat pump’s energy and electricity consumption.
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App Usage Data: Details about your interactions with the mobile app and software platform, including login times, feature usage, and preferences.
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Technical Data: Device information and IP address related to secure use of our app.
2. Purpose and Legal Basis for Processing
We process this data to:
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Provide and maintain your Homely Hub service.
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To support the operation of your heat pump in accordance with your preferences.
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Improve our products and services.
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Fulfil our contractual obligations under your Homely Hub End User Licence Agreement.
Our lawful bases for processing this data include contractual necessity, legitimate interests, and your consent where applicable (e.g., for preference setting and electricity consumption).
3. Data Recipients
We share your personal data with the following categories of recipients, where necessary:
- Service providers assisting with hosting, IT support, and data analysis.
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Third parties involved in the installation and maintenance of your heat pump system.
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Regulatory bodies, if required by law.
4. Data Retention
Your personal data is retained for as long as necessary to provide the Homely Hub service and comply with legal and regulatory obligations.
5. Copy of Personal Data
Please find the attached CSV and xlsx files to this email that contain a copy of your personal data held in our systems as requested.
6. Data about the heat pump
We understand that the intention of your request may be to obtain data about the operation of the heat pump. Therefore, we want to provide some further explanation as to the data we have provided in response.
Under UK GDPR, personal data is data which relates to an individual. On this basis our response contains data which:
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Is clearly about you (e.g. account information)
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relates to your choices (e.g. temperature selection and scheduling)
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is data which impacts you or your household, or is an evaluation about you (e.g. electricity consumption or energy consumption)
However, technical data about the heat pump operations which is used to maintain it efficiently and effectively, is not personal data (e.g. flow rate). The ICO provides guidance that ‘information about the operation of a piece of machinery…. is unlikely to be personal data’. (https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/personal-information-what-is-it/what-is-personal-data/what-is-the-meaning-of-relates-to)
Such technical data does not directly describe, assess, or relate to a person's identity or activities, nor does not influence or alter your rights, obligations or behaviour. Therefore, we believe we are aligned with both the UK GDPR and ICO guidance when not viewing such technical data on the heat pump functioning as personal data, and not disclosing it.
It is worth noting that, whilst not related to the decision making under this request, there is a risk of misuse of technical data, on purpose or by accident, by people who are not trained installers and individuals.
7. Your Rights
In addition to accessing your data, you have the right to:
- Request correction of inaccurate or incomplete data.
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Request erasure of your data in certain circumstances.
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Object to or restrict certain processing activities.
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Lodge a complaint with the Information Commissioner’s Office (ICO) if you believe your data rights have been infringed (www.ico.org.uk).
Next Steps
If you have any questions or require further clarification regarding this response, please contact us using team@homelyenergy.com or write to us at the address above.
We understand you are disappointed that you do not have access to the data visibility you would like from Homely. However Homely is not intended to be a monitoring device and our core service proposition is the smart control of heating through our advanced optimisation algorithms to deliver an efficient and comfortable heating experience for our customers. We do understand that some customers would like to see more information about how their heat pump is performing and this is something our product teams are exploring as part of our future product roadmap. At this stage we cannot confirm a timeline for this or what the end solution will look like but once ready we will let all our customers know. If you decide the Homely product isn’t providing you with the service you require, we can offer you a full refund up to the current RRP of Homely (£199) in exchange for the products return. If this is something you would like to do, please let me know within the next 30 days.
Thank you for reaching out to us. We are committed to respecting your privacy and ensuring transparency in how we handle your personal data.