Metis Privacy Policy

1. Introduction

Metis Energy Limited (“we”, “us”, “our”) is committed to protecting your privacy and handling your personal data in accordance with applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. This policy (“Privacy Policy”)  explains how we collect, use, store, and protect your personal information that you, or others provide to us (“you”).

We process your information when you use the Energy Saver Website (“Website”) or Energy Saver App (“App”). The Privacy Policy applies to your use of either the Website or the App.

We are the data controller of any personal information you provide when using the Website or the App.

2. What information we collect  

The personal information we collect about you depends on the particular context in which it is processed. We collect personal information about you only where we have a reason for doing so and only where that reason is permitted under data protection law (see the section below ‘Lawful basis for processing’). This section of this Privacy Policy sets out what personal information we collect about you. Where you create an account and use the services provided on the Website or App we will collect information including the following:

• your name, address, date of birth, gender, email address, phone number, 
• energy consumption and tariff data (including half hourly energy consumption data),
• where applicable, payment details such as credit or debit card information or direct debit details, 
• information to enable us to undertake credit or financial checks on you,
• information provided to us by credit reference agencies,
• details relating to your property,  
• technical information including device identifier numbers (such as IMEI numbers and IP address) and login information.

We may also require details of any needs of you or others in your household such as age, health or vulnerability status to the extent it may be relevant for the carrying out of the services (for example, a disability), to ensure that the service we provide and health and safety considerations are tailored to such circumstances.

3. Lawful basis for data processing

Under data protection law, we can only use your personal information if we have a legal basis to do so.

Where the processing is based on consent, you have the right to withdraw your consent at any time. This will not affect the validity of the processing of your personal information prior to the withdrawal of consent.

Where we process your personal information on the basis of legitimate interests, we carry out a balancing test in accordance with our obligations under data protection law to ensure that our processing is necessary and is not outweighed by your privacy rights.

We may process your information where that is necessary to perform a contract with you as the data subject and/or in order to take steps at the request of a data subject prior to entering into a contract.

We may also process your information where that processing is necessary to comply with a legal obligation.

4. Why we use this information and the basis for using (processing) this information

When you use the App or Website and where you purchase products and/or services from us directly we will use your personal information for the following purposes:

• Marketing Information and communications

We use your information to provide marketing communications and notifications to you, either from us or from third party providers in relation to products which may be of interest to you, or to provide you with services related to the provision of energy savings either by us or third-party providers including energy comparison sites or energy suppliers.

Lawful basis for Processing: 

We rely on your consent to send you marketing communications. When you register with the Energy Saver App you have the option to tick the consent form to signal your consent to receiving marketing communications.  You are entitled to withdraw your consent to receiving marketing communications at any time however this may impact our ability to continue to deliver products and services to you in the same way.  We may also provide marketing communications and notifications to you where we have previously contracted with you for goods or services or where you have previously expressed an interest in purchasing our products or services or taken part in a free trial.

• To provide necessary sales or comparison information or quotes to you to purchase any product or services offered

In order to provide services to you we require to share your information with third parties who are able to provide information showing energy usage at your home with relevant comparison information to show potential energy savings.

Lawful basis for Processing:  

It is in our legitimate interests to be able to show you comparison data to allow you to use the App in an informed way when choosing to access any products or services which may be offered to you. We may also require to process your information in order to take steps at the request of you as the data subject prior to entering into a contract. 

• To provide any comparison or switching services or information based on energy usage to allow you to purchase our or third-party services 

Where you wish to purchase services from us or through the App we will require to process your information to put in place the appropriate contract for the provision of any services purchased. 

Lawful basis for Processing:  

When you choose to purchase products or services from the App or Website we will do this on the basis of a contract that you will require to enter into to receive such products or services. It is also in our legitimate interest to show you details of any comparison data to allow you to use the App in an informed manner. We may also require to process your information in order to take steps at the request of you as the data subject prior to entering into a contract.

• To provide half hourly smart meter data 

In connection with the products or services provided by us, your energy supplier or other third party, we may require to collect your energy consumption data on a half hourly basis (every half an hour). This information will be used to provide the products or services to you, your energy supplier or other third party including to produce improved calculations of your energy consumption.

You are entitled to withdraw your consent to us obtaining your half hourly consumption data at any time however this may impact our ability to continue to deliver products and services to you in the same way.

We may also require to verify your identity in order to obtain your half-hourly consumption data through obtaining a copy of your energy bill and/or photographic ID and to do this, we may use third party service providers.

Lawful basis for Processing:  

When you choose to purchase products or services from the App or Website we will do this on the basis of a contract that you will require to enter into to receive such products or services.  It is also in our legitimate interest to use such data to ensure that the most appropriate products or services are provided to you. We may also require to process your information in order to take steps at the request of you as the data subject prior to entering into a contract.

• When you email and phone us

When you phone or email us with general queries (i.e. not those related to products or services provided to us or services provided by us to a third party, such as your energy supplier), we may process your personal information in order to provide us with the information you have requested.

The details we may collect include, your name, email address, telephone number and other personal information you have given us. This may also include us keeping a record of your interaction with us including recording telephone calls or taking a record of correspondence.

Lawful basis for Processing:  

We have a legitimate interest as a business to ensure that we are able to satisfactorily answer any queries or questions you may have in relation to the App or Website to provide a satisfactory user experience. We may also require to process your information in order to take steps at the request of you as the data subject prior to entering into a contract. 

• To continue to provide services to you and administer your account;

We will process your information to ensure that our App and Website are able to provide a satisfactory user experience and provide the most appropriate products and services to you. We also require to be able to ensure that we notify you properly in relation to any changes or amendment to the App or Website or our Privacy Policy.

Lawful basis for Processing:  

We require to process your information to perform our contract with you and provide services to you when using the App or Website. We have a legitimate interest as a business to ensure that we are able a satisfactory and high-quality user experience and to provide any updates or changes to you in a timely manner.

• To improve the Website and App to provide a more effective user experience

When you visit our website, we may require to collect personal information about you relating to your use of the Website and/or to provide you with a more effective user experience and/or to ensure the security of our Website. 

The details we collect may include, technical information including device identifier numbers (such as IMEI numbers and IP address), login information, browser type and version, time zone settings, plug-ins and operating systems as well as information about your visit including page response times, downloads and interaction methods.

You can ask us to stop using your personal information in this way by using the “do not track” functionality in your internet browser.

We may also share aggregated, anonymous data with third party providers including but not limited to analytics providers and search engine providers that assist us in the improvement and optimisation of our digital services.

Lawful basis for processing: 

it is in our legitimate interest to ensure that our service provision to you is as secure as possible and provides you with a satisfactory user experience.

For further information on how we use cookies on our website, please see here: Cookie Policy | SMS

• Complying with legal and regulatory obligations for example with consumer protection law and the contract between us or to detect and prevent fraud, criminal activity or misuse

We may provide information where necessary to comply with any legal obligations to which we are subject to, or to help detect or prevent crime, or the App or Website being used in the commission of crime.

Lawful basis for processing: if we process your information in this way we will do so on the basis that it is to comply with our legal obligations and also in the public interest where such processing is in relation to the detection or prevention of crime. 

5. Sharing Your Information

Where we share your personal information with third parties, we do so in line with this Privacy Policy and in compliance with data protection laws as well as the agreement between us. Your information will only be shared with third parties that we trust. Some of the organisations we may share your personal information with may include:

• Our group companies and affiliates, where necessary for the provision of our services. This includes all subsidiaries of Smart Metering Systems Limited, including SMS Meter Assets Limited, SMS Data Management Limited, SMS Energy Services Limited, CH4 Gas Utility and Maintenance Services Limited, Solo Energy Limited, N3rgy Data Limited; 
• Third parties and business partners we use to help deliver our products and services to you (e.g. suppliers, and payment service providers);
• Third parties approved by you (e.g. social media sites you choose to link your account to or third-party providers);
• Professional advisers e.g.  insurers or our external auditors (for example in relation to the audit of our accounts) in which case the recipient of the information will be bound by confidentiality obligations;
• Outsourced service providers (e.g. call centre services, IT service providers, payment providers or otherwise);
• The Financial Conduct Authority;
• Credit reference agencies, identity verification providers and fraud prevention agencies;
• Debt collection agencies where we have a legitimate interest to recover sums owed to us for our products or services;
• The Smart Energy Code (SEC) who may periodically audit the provision of the services we provide;
• Cloud service providers.

We may also be obliged to disclose personal information to any competent legal or regulatory authority conducting an investigation in relation to criminal activity or law enforcement agency, courts, tribunals.

The third parties mentioned above occasionally also share personal information with their external auditors and their professional advisors (such as lawyers and other advisors).

For more information regarding our use of your personal information for the purposes of credit reference checks via external credit reference agencies, please see our external provider (Experian)’s Credit Reference Agency Information Notice - Credit Reference Agency Information Notice (CRAIN) | Experian. This Privacy Policy contains further details regarding how credit reference agencies use and distribute your personal information.  We may require credit references to help us trace you if you have moved and owe us any money.

Throughout our website, we may link to other websites owned and operated by certain trusted third parties to make additional products and services available to you. Those third-party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third-party websites, please consult their privacy policies as appropriate.

6. Transferring personal information outside of the UK or EEA

In connection with some of the services we provide, we (or a third party who we share personal information with) may require process your personal information outside of the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal information and the contract between us.

When we send personal information outside of the UK/EEA, we will make sure that the correct safeguards have been put in place to protect your personal information, including:

• ensuring that the country where any data will be transferred to is subject to an “adequacy decision” by the UK government and/or European Commission. This is to ensure that the particular country ensures an adequate level of protection of personal information under their domestic laws; or
• ensuring that there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
• a specific exception applies under relevant data protection law; or
• ensuring that standard, legally approved, data protection clauses recognised or issued further to Article 46(2) of the UK GDPR or EU GDPR (as applicable) are included in our contracts with those third parties.

In the event we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your personal information outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this Privacy Policy.

7. Data Security

We implement industry-standard security measures to protect your data from unauthorised access, loss, or disclosure. Access to personal data is restricted to authorised personnel only.

8. How long we keep your information

We keep personal information only for so long as we need it. Once we no longer need it, we arrange for it to be deleted from our systems. We may retain certain personal information for legal or regulatory purposes only.

In determining the appropriate retention period for the personal information we hold, we consider the amount, nature and sensitivity of the personal information, the risk of harm from unauthorised use or disclosure of your personal information as well as the applicable legal requirements under data protection law and otherwise.

In some circumstances, we might anonymise your data (so that it can no longer be associated with you) and use this indefinitely without further notice to you.

9. Your Rights

You have the following rights under data protection law:

Right of access – you have the right to request a copy of your personal information that we process and you are entitled to receive confirmation about whether your personal information is being processed by us;

Right to rectification – you have the right to request that your personal information is updated where you consider it is inaccurate or incomplete;

Right to object – you have the right to object to us handling your personal information where we are handling your personal information in certain circumstances;

Right of erasure – you have the right to ask us to erase your personal information in certain circumstances;

Right to restriction of processing – you have the right to ask us to restrict the processing of your personal information in certain circumstances; and

Right to data portability – you have the right to ask that we transfer the personal information to another organisation, or to you, only where we are processing your personal information because you have consented to us using it or where there is a contract in place between us. 

For more information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.

10. Cookies and Tracking

We use cookies and similar technologies to enhance your experience and analyse usage. Further information is available in our Cookies Policy [here]. 

11. Changes to This Policy

We may update this policy from time to time. If there are any changes to the way we use personal information, we will update this Privacy Policy on our website. The latest version will always be available on the Website and App. This Privacy Policy was last updated in November 2025.

12. Contact Us

How to contact us 

To get in touch with us about any of the above (including if you have any questions about this Privacy Policy or the information we hold about you, to exercise a right under data protection law or to make a complaint) please email or write to our data protection officer at: dpo@smsenergy.com or Data Protection Officer, Smart Metering Systems Limited, 2nd Floor, 48 St Vincent Street, Glasgow, G2 5TS.

Information Commissioner’s Office

Please contact us if you have any queries or concerns about our use of your personal information (see above ‘How to contact us’). We hope we will be able to resolve any issues you may have.

If an individual is not happy with our reply to any complaint or thinks our processing of their personal information doesn’t comply with data protection law, a complaint can be made to the Information Commissioner’s Office (ICO). Just use these details:

Address: Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF

Telephone number: 0303 123 1113

Web: Information Commissioner's Office