Last updated May , 2018
One Big Switch, LLC (“One Big Switch,” “we,” “our,” or “us”) is a “for profit” company that operates a member network. Amongst other things, we source potential discounts and group switching opportunities for our members for a range of consumer products, services and utilities. We receive a commission or fee from the third-party providers of products, services or utilities when One Big Switch members take up that product, service or utility.
This policy can be accessed from our
website http://www.onebigswitch.com.Should you require a copy of this policy in another form please contact us via the contact details set out at the end of the policy and let us know.
In this policy a reference to:
a “Third-Party Partner” means
a. provider, supplier or distributor (or potential provider, supplier or distributor) of a product, service or utility which is (or potentially will be) partnered with us for the purpose of facilitating or initiating the offerings and switching opportunities made to our members; or
b. person or entity who assists us for the purpose of facilitating or initiating, the offerings and switching opportunities made to our members.
Third-Party Partners include (but are not be limited to) intermediaries, energy suppliers and other utilities, insurance companies, telecommunications companies, credit providers and/or other lenders, brokers, financial institutions, consumer product and service providers, accountants, credit reporting agencies, credit representatives and lawyers.
“Personal information” means any information or opinion about you from which your identity is apparent (including any photographs or information you upload on our website), or can reasonably be ascertained.
Personal information can also include sensitive information. “Sensitive information” is information or an opinion about matters such as your racial or ethnic origin, political persuasion, religious or philosophical beliefs, memberships in trade or professional associations or trade unions, sexual orientation or practices, criminal record, or health information.
The types of personal information we commonly collect for the purpose of our functions and activities include (without limitation):
- identifying and contact information (e.g., name, age, date of birth, employment details, telephone number, and/or email address);
- financial information (e.g., bank account details); and
- consumer-related information on household spending, insurance needs and/or energy consumption.
This policy applies to personal information we collect from or about you. This may occur when you:
- use our website;
- register your interest with One Big Switch;
- become or remain a member of One Big Switch;
- contact One Big Switch;
- participate in a One Big Switch campaign;
- upload any photos or information about yourself on our website;
- apply for a job with us; or
- provide your personal information to us in any other way
We will generally collect personal information directly from you.
We may obtain your personal information via a Third-Party Partner.
We may also collect photographs and/or personal information you upload on our website during the course of a campaign or from our usual activities. One Big Switch may post and use your photographs and/or personal information (“User Content”) both on its website, its social media sites (including Facebook) and in any other content or copy we may use for the purpose of our functions, activities and/or campaigns (unless, in relation to direct marketing, you ask us not to). By uploading photographs to our website, you grant us a worldwide, non-exclusive, sublicensable, royalty-free license in to copy, publish, use, and distribute your User Content, and create derivative works based on your User Content.
If you do not provide the personal information requested by us or a Third-Party Partner, you may be unable to enjoy the full benefits of membership with One Big Switch, or participate in, or be notified of, relevant offerings and switching opportunities.
We collect personal information (including sensitive information) about our members or potential members and job applicants in order to conduct our business of sourcing, identifying and referring potential member discounts or discount related products or group or individual switching opportunities for our members, and offering (sometimes via our third party partners) and marketing those discounts and opportunities to our members and potential members.
Collected personal information is used to facilitate One Big Switch’s functions and activities including (without limitation):
- to source and identify potential member discounts or group switching opportunities;
- to provide you with information regarding current and future offerings or switching opportunities which we think may be of interest to you;
- to compile data and conduct analysis of member statistics;
- to develop our business and operational processes for delivering potential group discount offers and group switching opportunities;
- to manage our ongoing relationship with our members;
- to share experiences, commentary and feedback provided by our members on our website, our social media platforms (including Facebook and Twitter) and in our member emails;
- to make submissions to governmental departments, private sector organizations or to publish commentary or studies in support of legislative or other private sector reform;
- to administer and process member participation in offerings and switching opportunities;
- to resolve any legal and / or commercial complaints or issues;
- to assess a job applicant and to allow us to carry out any monitoring activities which may be required of us under applicable law as an employer; and
- to comply with legal requirements.
- disclosure is to one of our Third-Party Partners;
- we have your consent;
if we are under a legal or regulatory obligation to do so (for example, in response to a subpoena) or to protect the rights and interests, property, or safety of One Big Switch, our members or others;
all, or substantially all, the assets of One Big Switch are merged with or acquired by a Third-Party, in which case your personal information may form part of the transferred or merged assets;
we provide or share aggregate or bulk data (such as information about market trends and consumer choice) with other reputable third parties. If we do this, personal information, which might identify a particular One Big Switch member, will not form part of the aggregate or bulk data;
we provide stories, commentary or share photos or other personal information you have uploaded on our website onto other social media channels associated with One Big Switch (including Facebook);
- we use a Third-Party service provider to provide services that involve data processing, for example archival, auditing, professional advisory (including legal, accounting, financial and business consulting), mailing house, delivery, technology, website, research, banking, payment, data processing, insurance, marketing and security services.
Where possible, we will inform you, at or before the time of collecting your personal information about other types of organizations to whom we may, with your consent, disclose your personal information. Prior to such disclosures, One Big Switch will take all reasonable steps to satisfy ourselves that:
the organization has a commitment to protecting your personal information; and where necessary, you have consented to such disclosure.
We or a Third-Party Partner may use your personal information to contact you about, among other things:
- potential member discount offers and group switching opportunities for consumer products, services, financial and insurance products, and utilities which we think may be of interest to you;
- changes to our organization;
- new products, services, utilities or switching opportunities being offered to our members through us or in combination with any Third-Party Partner; or
- your membership or potential membership.
You may be contacted in various ways including, but not limited to, email, SMS, instant messaging, telephone, multimedia messaging or other form of electronic communication.
If you do not wish to receive marketing information or be contacted for the purposes outlined above, you can opt out at any time. If you wish to opt out, please contact us via the contact details at the end of this policy and provide us with details of the communication that you no longer wish to receive and your request to be removed from the relevant mailing list. We will take all reasonable steps to meet your request at the earliest possible opportunity.
You may request access to, and/or correction of, any of the personal information we hold about you at any time by contacting us via the contact details at the end of this policy.
There may be reasonable charges associated with giving you access to your personal information, for example if an extended amount of time is required to collate and prepare material in response to your request. No charge is applied in relation to making a request.
Access to your personal information may be denied on certain grounds including, for example: it is unlawful; it may have an unreasonable impact upon the privacy of other individuals; or your request is frivolous or vexatious. If we deny you access we will provide our reason for doing so.
In order for us to successfully do business with you it will not, in most circumstances, be practical for us to deal with you without you providing relevant personal information to us. However, where it is lawful and practicable to do so, you may deal with us anonymously or by using a pseudonym. Such a situation might include where you make a general inquiry about energy prices, interest or insurance rates, current member offers, potential member discounts or group switching opportunities
We will take reasonable steps to protect your personal information by storing it in a secure environment, usually electronically on our servers.
We will also take reasonable steps to protect any personal information from misuse, loss, and unauthorized access, modification or disclosure, including by implementing security procedures for access to our business premises and within our offices, as well as IT security procedures including password protection, firewalls and site monitoring.
However, data protection measures are never completely secure, particularly in circumstances where information is transferred via the Internet. We cannot guarantee the security of your information and you must take care to protect your personal information, for example by securely storing your username and password information. You should notify us as soon as possible if you become aware of any security breach.
We will not use government identifiers (e.g., your social security number) as our own identifier for you. We will only use or disclose such identifiers as permitted under relevant privacy legislation.
13. International Visitors
This website is hosted in the United States and is intended solely for visitors located within the United States. The products and services we offer are intended for users located within the United States only.
We do not allow minors under 18 years of age to use the Services or knowingly collect or maintain personally identifiable information from persons under 13 years of age, and no part of the Services is directed to persons under 18 years of age. If you are under 13 years of age, then please do not use or access the Services at any time or in any manner. If we learn that personal information has been collected on the Services from persons under 13 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 13 years of age has become a member or provided us with personal information, then you may alert us at email@example.com request that we delete the personal information from our systems.
If you have any concerns regarding our compliance with relevant privacy or spam legislation please contact us via email using the contact details at the end of this policy. Your email should set out details of your concerns, and attach any supporting evidence.
When we receive your email, we will investigate the issue internally and contact you within a reasonable time to inform you of the further steps, if any, we will take to resolve your complaint. We may ask you for further information about your complaint. We will notify you in writing of the outcome of our investigation as soon as practicable.
Please contact us at our offices via the contact details provided below if you want to:
- obtain further information about the way we manage your personal information;
- raise a concern or make a complaint regarding how we collect or handle of your personal information;
- correct or update your personal information held by us;
- unsubscribe from any One Big Switch mailing list or have any questions or complaints regarding unsolicited electronic communications which you may have received or are concerned about.
One Big Switch, LLC
1732 1st Ave Apt 23199
New York NY 10128-5177
Attention: Privacy Department
Residents of California and have provided their personal information to us are entitled to request information regarding our disclosures, if any, of their personal information to third parties for direct marketing purposes. Such requests must be submitted to us at firstname.lastname@example.org
One Big Switch LLC 1732 1st Ave Apt 23199
New York NY 10128-5177
Attention: Privacy Department
California privacy rights requests must include the email address or mailing address, as applicable, for us to send our response. This request may be made no more than once per calendar year.