Privacy Policy

WEBSITE PRIVACY POLICY

Last updated: 30/04/2026

SEGEN LIMITED

INTRODUCTION

At Segen we take your privacy seriously and we are committed to protecting it.

This policy explains when and why we collect or receive personal information about you when you visit our website, how this information is used, with whom we share that information and the rights they have over it. This policy was last updated on the date set out at the top of this page.

If you are an installer or other distributor and place an order using our website, please also see our Customer Privacy Policy which describes how we handle your personal information when receiving, processing and fulfilling your orders.

If you are a homeowner or other end user of our products supplied to you by one of our customers, please also see our End User Privacy Policy.

WHO WE ARE AND OUR ROLE

We are Segen Limited (we/us/our) and, for the purposes of UK data protection laws, we are the controller of the processing activities described below in this policy.

A controller is a person that decides why and how your personal information is processed. As the controller, we are responsible to you for the handling and treatment of that information.

Please see the section at the end of this policy for our contact and company information.

HOW WE COLLECT YOUR PERSONAL INFORMATION

We receive personal information about you in a variety of ways when you use our website.

Personal information you give to us voluntarily

This is information about you that you give to us when:

  • completing webforms on our website, including to make enquiries or complete surveys; and
  • corresponding with us by phone, email or in another way.

This information is provided by you entirely voluntarily.  If we do not receive this information, you may be unable to communicate with us effectively or unable to receive products purchased through the installer.

Information we collect about you including using automated methods

We may automatically collect information about your use of our website, such as the number and duration of visits to our website and details of which particular pages or parts have been visited. We may also anonymise any personal information we receive about you by amending it, combining it with other data or by using other anonymisation techniques (Anonymised Information). After we anonymise your information, it will not be attributable to you.

We also automatically collect technical information, including Internet protocol (IP) addresses used to connect your device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform as well as mobile identifiers cookie, tracking pixel and beacon identification information. Please see our Cookie Policy for further information (Technical Information).

We use any collected Technical Information and Anonymised Information to analyse how our website is functioning and how it is used by users, for insight purposes and to help us maintain and improve our website on an ongoing basis. We may share Technical Information and Anonymised Information with third parties with whom we work, including our commercial partners.

THE PERSONAL INFORMATION WE PROCESS ABOUT YOU

We may process the following types of personal information about you, which we have categorised as follows:

Category of personal information

Description

Behavioural

information about how you use and interact with websites and services, including your preferences, interests, browsing activity and engagement patterns.

Contact

information which can be used to address, send or otherwise  communicate a message to you such as your name, telephone number, address and email address.

Correspondence

information contained in our correspondence or other communications with you.

Identity

information contained in a formal identification document or other  unique reference number relating to you.

Technical

technical information relating to your visit to our website, including IP address and cookie data.


HOW WE USE YOUR PERSONAL INFORMATION

UK data protection laws require us to have a valid reason to process your personal information for each of the different purposes for which we use that information. These laws refer to each reason as a ‘lawful basis’. The purposes for which we use your personal information are explained below, together with the lawful basis under UK data protection laws on which we rely to do this.

Where you have provided consent

We may use and process your personal information where you have consented for us to do so for the following purposes:

  • in relation to any personal email address or mobile number we hold, to make electronic marketing communications including by email, SMS and, in relation to our mobile apps, push notices; and
  • any purpose we communicate to you at the time you opt-in to allow us to process your personal

We also process personal information we obtain from non-essential cookies that we set on our website based on your consent.  For more information, please see our Cookie Policy.

Where processing is necessary for us to pursue our legitimate interests

We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business, for the following purposes:

Processing necessary for our legitimate interests in promoting our products and services and our business

  • to contact you from time to time with marketing information where the law allows us to do so without your consent e.g. by telephone or to your work email address or work mobile number (you have the right to object to us using your personal information for this purpose at any time);

Processing necessary for us to respond to changing market conditions and our customers’ and website users’ needs 

  • for market research, insight and intelligence in order to improve our understanding of you or your business;

Processing necessary for our legitimate interests in to operate the administrative and technical aspects of our business efficiently and effectively

  • to administer our website and for our internal operations, including troubleshooting, testing and statistical reporting purposes;
  • for the detection and prevention of fraud and other criminal activities;
  • to verify the accuracy of information we hold about you;
  • for network and information security purposes in order for us to take steps to protect your and our information and property against loss or damage, theft or unauthorised access;
  • to comply with a request from you in connection with the exercise of your rights where required under applicable data protection law;
  • for the purposes of a corporate restructure or reorganisation or sale of our business or assets;
  • for efficiency, accuracy or other improvements of our databases and systems e.g. by combining systems or consolidating records we hold about you;
  • to place and read cookies that are essential for our website to function properly, as described in our Cookie Policy;
  • to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings;
  • for general administration including financial planning, control and reporting and managing your queries, complaints, or claims, to send service messages and to provide you with important information about our business.

Where required to comply with our legal obligations

We will use your personal information to comply with our legal obligations:

  • to assist any public authority or criminal investigatory body, where we are under a legal obligation to do so;
  • to identify you when you contact us where we are obliged under applicable law to do so;
  • to verify the accuracy of data we hold about you; and
  • to respond to and resolve your complaints in relation to our services where we are obliged under applicable law to do so.

OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL INFORMATION

Other companies in our group

We may share your information with other companies in our group and they may use your personal information for the purposes and ways set out in “How we use your personal information”, in connection with the services they provide, including where they complement our own services.

Our suppliers, service providers and other recipients

We may share your information with our third party service providers, agents, subcontractors and other organisations (as listed below) for the purposes of providing services to us or directly to you on our behalf.

Recipient / relationship to us

Industry sector (& sub-sector)

Accountancy and auditing services

Professional services (accountancy)

Cloud storage service providers

IT (cloud services)

Government tax administration offices

Government (tax)

Haulage and delivery service providers

Logistics (haulage/delivery)

Installers

Energy (installation services)

Insurance services providers

Insurance (brokers/underwriting/experts)

Legal advisers

Professional services (legal services)

Data analytics and platform providers

IT (analytics)

Website development and related service providers

IT (online services)


When we use third party service providers as our data processors, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.

When we share your personal information with third parties that are controllers of that information, they may disclose or transfer it to other organisations in accordance with their data protection policies. This does not affect any of your data subject rights as detailed below. In particular, where you ask us to rectify, erase or restrict the processing of your information, we take reasonable steps to pass this request on to any such third parties with whom we have shared your personal information.

Other ways we may share your personal information

We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. We may also transfer your personal information to public authorities, courts or tribunals if we are under a duty to disclose or share it in order to comply with any legal obligation, to detect, prevent or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our customers. This may involve disclosing your personal information to our customers, the police and other public authorities, criminal investigatory bodies, courts, regulators or the emergency services.  We will always take steps with the aim of ensuring that your privacy rights continue to be protected.

WHERE WE STORE YOUR PERSONAL INFORMATION

Information you provide to us may be transferred to countries outside the UK, including to companies in our group or if any of our servers or those of our third party service providers are from time to time located outside the UK. These countries may not have data protection laws similar to those of the UK and so may not protect the use of your personal information to the same standard.

If we transfer your information outside of the UK, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this policy. These steps include:

  • relying on adequacy decisions issued by the relevant UK Secretary of State where we send personal data to Andorra, Argentina, commercial organisations in Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Jersey, New Zealand, Switzerland, Uruguay, Japan, South Korea, Gibraltar or the Economic European Areas;
  • where the above does not apply, all transfers of personal data between our group companies rely on the UK International Data Transfer Agreement or Addendum issued by the Information Commissioner’s Office;
  • for transfers to US entities, relying on the EU-US Data Privacy Framework and the UK-US Data Bridge that extends that framework to the UK, where such entities are registered with the EU-US Data Privacy Framework;
  • in a limited number of circumstances, relying on binding corporate rules; and
  • ensuring that the recipients are subscribed to ‘international frameworks’ that aim to ensure adequate protection, such as the UK-US Data Bridge that extends the EU-US Data Privacy Framework to the UK.

Please contact us using the details at the end of this policy for more information about the protections that we put in place and to obtain a copy of the relevant documents.

SECURITY

We care about protecting your information. We put in place appropriate measures that are designed to prevent unauthorised or unlawful processing and accidental loss, destruction, or damage. We do this by having in place a range of appropriate technical and organisational measures, including encryption measures and disaster recovery plans.

HOW LONG WE KEEP YOUR PERSONAL INFORMATION FOR

The length of time for which we retain your personal information is determined by a number of factors including the purpose for which we use that information and our obligations under data protection and other laws in the jurisdictions that apply to us. We do not retain personal information for longer than is necessary for our processing purposes or for longer than the law otherwise permits.

We will usually retain your personal information 7 years after the date it is no longer needed by us for any of the purposes listed above under How we use your personal information. We may derogate from this retention period in the following circumstances:

  • you exercise your right to require us to retain your personal information for a period longer than our stated retention period (see further Erasing your personal information or restricting its processing);
  • you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see further Erasing your personal information or restricting its processing below);
  • we bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible; or
  • in limited cases, existing or future law or a court or regulator requires us to keep your personal information for a longer or shorter period.

AUTOMATED DECISION MAKING

We do not envisage that any decisions that have a legal or significant effect on you will be taken about you using purely automated means, however we will update this policy and inform you if this position changes.

YOUR RIGHTS

You have certain rights in relation to your personal information.  In relation to certain rights, we may ask you for further information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within one month from either the date that we have confirmed your identity or, where we do not need to do this because we already have this information, from the date we received your request.

Where the law permits, we may charge a reasonable administration fee to fulfil your rights request, or in rare cases may reject part or all of your request, where it is manifestly unfounded, or excessive (for example, in the case of repetitive or overlapping requests).

  • Accessing your personal information

You have the right to ask for a copy of the personal data that we hold about you (e.g., by emailing or writing to us at the address at the end of this policy).  Where provided for under the applicable data protection law, we may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.

  • Correcting and updating your personal information

The accuracy of your information is important to us and we are working on ways to make it easier for you to review and correct the information that we hold about you.

In the meantime, if you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, please let us know by contacting us via any of the details described at the end of this policy.

  • Withdrawing your consent

Where we rely on your consent as the legal basis for processing your personal information, as set out under “How we use your personal information”, you may withdraw your consent at any time by contacting us using the details at the end of this policy.  If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can do so, for example, using our unsubscribe tool. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.

  • Objecting to our use of your personal information

Where we rely on your legitimate business interests as the legal basis for processing your personal information for any purpose(s), as out under “How we use your personal information”, you may object to us using your personal information for these purposes, e.g., by emailing or writing to us at the address at the end of this policy. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise, we will provide you with our justification as to why we need to continue using your data.

You may object to us using your personal information for direct marketing purposes and we will automatically comply with your request. If you would like to do so, please use our unsubscribe tool.

  • Erasing your personal information or restricting its processing

In certain circumstances, you may ask for your personal information to be removed from our systems (e.g., by emailing or writing to us at the address at the end of this policy). Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request.

You may also ask us to restrict processing your personal information where you believe it is unlawful for us to continue processing, you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings.  In these situations we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings. 

  • Transferring your personal information in a structured data file ('data portability’)

Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out under “How we use your personal information”, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine-readable form, such as a CSV file.

You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.

  • Complaining to the data protection regulator

You have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the data protection regulator in the UK.  However, we encourage you to contact us before making any complaint and we will seek to resolve any issues or concerns you may have.

The contact details for the ICO are below:

Post:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Phone:

0303 123 1113

Email:

casework@ico.org.uk

CHANGES TO THIS POLICY

We may update this policy from time to time. We recommend you regularly check for changes and review all updates to this policy

CONTACT AND COMPANY INFORMATION

Please direct any queries about this policy or about the way we process your personal information to our data protection team using our contact details below.

If you wish to write to us, please write to Data Protection, Segen Limited, 200 Fowler Avenue, Farnborough, England, GU14 7JP.

Our email address for data protection queries is info@segen.co.uk.

Segen Limited is a limited liability company incorporated in England and Wales with company number 05309114 with its registered office address at 200 Fowler Avenue, Farnborough, England, GU14 7JP.

PRIVACY POLICY FOR END USERS

Last updated: 30/04/2026

SEGEN LIMITED

INTRODUCTION

At Segen we take your privacy seriously and we are committed to protecting it.

This policy explains when and why we collect or receive personal information about you as a homeowner (or other end user of our products), how this information is used, with whom we share that information and the rights they have over it. This policy was last updated on the date set out at the top of this page.

WHO WE ARE AND OUR ROLE

We are Segen Limited (we/us/our) and, for the purposes of UK data protection laws, we are the controller of the processing activities described below in this policy.

A controller is a person that decides why and how your personal information is processed. As the controller, we are responsible to you for the handling and treatment of that information.

Please see the section at the end of this policy for our contact and company information.

HOW WE COLLECT YOUR PERSONAL INFORMATION

We collect personal information about you that you give to us when:

  • corresponding with us by phone, email or in another way;
  • visiting our offices, or other premises;  and
  • interacting with us at events or in connection with promotions we run from time to time.

This information is provided by you entirely voluntarily.  If we do not receive this information, you may be unable to communicate with us effectively or unable to receive products purchased through the installer.

THE PERSONAL INFORMATION WE PROCESS ABOUT YOU

We may process the following types of personal information about you, which we have categorised as follows:

Category of personal information

Description

Contact

information which can be used to address, send or otherwise  communicate a message to you such as your name, telephone number, home address (including postcode) and email address.

Correspondence

information contained in our correspondence or other communications with you.

Identity

information contained in a formal identification document or other  unique reference number relating to you.

Transactional

information relating to transactions or business interactions with or involving you including details of your installer and details of the survey(s) carried out at your property for you by an installer, including the time and date you received a visit from the installer.


HOW WE USE YOUR PERSONAL INFORMATION

UK data protection laws require us to have a valid reason to process your personal information for each of the different purposes for which we use that information. These laws refer to each reason as a ‘lawful basis’. The purposes for which we use your personal information are explained below, together with the lawful basis under UK data protection laws on which we rely to do this.

Where processing is necessary for us to pursue our legitimate interests

We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business, for the following purposes:

Processing necessary for our legitimate interests in promoting our products and services and our business

  • to contact you from time to time with marketing information where the law allows us to do so without your consent e.g. by telephone (you have the right to object to us using your personal information for this purpose at any time);

Processing necessary for our legitimate interests in to operate the administrative and technical aspects of our business efficiently and effectively

    • to enable us to send products to installers ordered by them in connection with their contract with you;
    • to verify the accuracy of information we hold about you;
    • for our internal operations, including troubleshooting, testing and statistical reporting purposes;
    • for the prevention and detection of fraud and other criminal activities;
    • to comply with a request from you in connection with the exercise of your rights where required under applicable data protection law;
    • for the purposes of a corporate restructure or reorganisation or sale of our business or assets;
    • for efficiency, accuracy or other improvements of our databases and systems e.g. by combining systems or consolidating records we or other companies in our group hold about you;
    • to maintain our or your compliance with our policies and procedures or to exercise our rights under them, including our anti-bribery, modern slavery, data protection, information security, and whistleblowing policies;
    • to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings;
    • to anonymise or pseudonymise your personal information, where appropriate, for example, to maintain the confidentiality of your communications with us; and
    • for general administration including financial planning, control and reporting and managing your queries, complaints, or claims, to send service messages and to provide you with important information about our business.

Where required to perform a contract with you or take pre-contractual steps you request

We will use your personal information to fulfil orders you place with installers or steps you request of the installer before placing an order that require us to process your personal information.

Where required to comply with our legal obligations

We will use your personal information to comply with our legal obligations:

  • to assist any public authority or criminal investigatory body, where we are under a legal obligation to do so;
  • to identify you when you contact us where we are obliged under applicable law to do so;
  • to verify the accuracy of data we hold about you; and
  • to respond to and resolve your complaints in relation to our services where we are obliged under applicable law to do so.

OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL INFORMATION

Other companies in our group

We may share your information with other companies in our group and they may use your personal information for the purposes and ways set out in “How we use your personal information”, in connection with the services they provide, including where they complement our own services.

Our suppliers, service providers and other recipients

We may share your information with our third party service providers, agents, subcontractors and other organisations (as listed below) for the purposes of providing services to us or directly to you on our behalf.

Recipient / relationship to us

Industry sector (& sub-sector)

Accountancy and auditing services

Professional services (accountancy)

Cloud storage service providers

IT (cloud services)

Government tax administration offices

Government (tax)

Haulage and delivery service providers

Logistics (haulage/delivery)

Installers

Energy (installation services)

Insurance services providers

Insurance (brokers/underwriting/experts)

Legal advisers

Professional services (legal services)


When we use third party service providers as our data processors, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.

When we share your personal information with third parties that are controllers of that information, they may disclose or transfer it to other organisations in accordance with their data protection policies. This does not affect any of your data subject rights as detailed below. In particular, where you ask us to rectify, erase or restrict the processing of your information, we take reasonable steps to pass this request on to any such third parties with whom we have shared your personal information.

Other ways we may share your personal information

We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. We may also transfer your personal information to public authorities, courts or tribunals if we are under a duty to disclose or share it in order to comply with any legal obligation, to detect, prevent or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our customers. This may involve disclosing your personal information to our customers, the police and other public authorities, criminal investigatory bodies, courts, regulators or the emergency services.  We will always take steps with the aim of ensuring that your privacy rights continue to be protected.

WHERE WE STORE YOUR PERSONAL INFORMATION

Information you provide to us may be transferred to countries outside the UK, including to companies in our group or if any of our servers or those of our third party service providers are from time to time located outside the UK. These countries may not have data protection laws similar to those of the UK and so may not protect the use of your personal information to the same standard.

If we transfer your information outside of the UK, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this policy. These steps include:

  • relying on adequacy decisions issued by the relevant UK Secretary of State where we send personal data to Andorra, Argentina, commercial organisations in Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Jersey, New Zealand, Switzerland, Uruguay, Japan, South Korea, Gibraltar or the Economic European Areas;
  • where the above does not apply, all transfers of personal data between our group companies rely on the UK International Data Transfer Agreement or Addendum issued by the Information Commissioner’s Office;
  • for transfers to US entities, relying on the EU-US Data Privacy Framework and the UK-US Data Bridge that extends that framework to the UK, where such entities are registered with the EU-US Data Privacy Framework;
  • in a limited number of circumstances, relying on binding corporate rules; and
  • ensuring that the recipients are subscribed to ‘international frameworks’ that aim to ensure adequate protection, such as the UK-US Data Bridge that extends the EU-US Data Privacy Framework to the UK.

Please contact us using the details at the end of this policy for more information about the protections that we put in place and to obtain a copy of the relevant documents.

SECURITY

We care about protecting your information. We put in place appropriate measures that are designed to prevent unauthorised or unlawful processing and accidental loss, destruction, or damage. We do this by having in place a range of appropriate technical and organisational measures, including encryption measures and disaster recovery plans.

HOW LONG WE KEEP YOUR PERSONAL INFORMATION FOR

The length of time for which we retain your personal information is determined by a number of factors including the purpose for which we use that information and our obligations under data protection and other laws in the jurisdictions that apply to us. We do not retain personal information for longer than is necessary for our processing purposes or for longer than the law otherwise permits.

We will usually retain your personal information 7 years after the date it is no longer needed by us for any of the purposes listed above under How we use your personal information. We may derogate from this retention period in the following circumstances:

  • you exercise your right to require us to retain your personal information for a period longer than our stated retention period (see further Erasing your personal information or restricting its processing);
  • you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see further Erasing your personal information or restricting its processing below);
  • we bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible; or
  • in limited cases, existing or future law or a court or regulator requires us to keep your personal information for a longer or shorter period.

AUTOMATED DECISION MAKING

We do not envisage that any decisions that have a legal or significant effect on you will be taken about you using purely automated means, however we will update this policy and inform you if this position changes.

YOUR RIGHTS

You have certain rights in relation to your personal information.  In relation to certain rights, we may ask you for further information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within one month from either the date that we have confirmed your identity or, where we do not need to do this because we already have this information, from the date we received your request.

Where the law permits, we may charge a reasonable administration fee to fulfil your rights request, or in rare cases may reject part or all of your request, where it is manifestly unfounded, or excessive (for example, in the case of repetitive or overlapping requests).

  • Accessing your personal information

You have the right to ask for a copy of the personal data that we hold about you (e.g., by emailing or writing to us at the address at the end of this policy).  Where provided for under the applicable data protection law, we may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.

  • Correcting and updating your personal information

The accuracy of your information is important to us and we are working on ways to make it easier for you to review and correct the information that we hold about you.

In the meantime, if you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, please let us know by contacting us via any of the details described at the end of this policy.

  • Withdrawing your consent

Where we rely on your consent as the legal basis for processing your personal information, as set out under “How we use your personal information”, you may withdraw your consent at any time by contacting us using the details at the end of this policy.  If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can do so, for example, using our unsubscribe tool. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.

  • Objecting to our use of your personal information

Where we rely on your legitimate business interests as the legal basis for processing your personal information for any purpose(s), as out under “How we use your personal information”, you may object to us using your personal information for these purposes, e.g., by emailing or writing to us at the address at the end of this policy. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise, we will provide you with our justification as to why we need to continue using your data.

You may object to us using your personal information for direct marketing purposes and we will automatically comply with your request. If you would like to do so, please use our unsubscribe tool.

  • Erasing your personal information or restricting its processing

In certain circumstances, you may ask for your personal information to be removed from our systems (e.g., by emailing or writing to us at the address at the end of this policy). Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request.

You may also ask us to restrict processing your personal information where you believe it is unlawful for us to continue processing, you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings.  In these situations we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings. 

  • Transferring your personal information in a structured data file ('data portability’)

Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out under “How we use your personal information”, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine-readable form, such as a CSV file.

You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.

  • Complaining to the data protection regulator

You have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the data protection regulator in the UK.  However, we encourage you to contact us before making any complaint and we will seek to resolve any issues or concerns you may have.

The contact details for the ICO are below:

Post:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Phone:

0303 123 1113

Email:

casework@ico.org.uk

CHANGES TO THIS POLICY

We may update this policy from time to time. We recommend you regularly check for changes and review all updates to this policy

CONTACT AND COMPANY INFORMATION

Please direct any queries about this policy or about the way we process your personal information to our data protection team using our contact details below.

If you wish to write to us, please write to Data Protection, Segen Limited, , 200 Fowler Avenue, Farnborough, England, GU14 7JP.

Our email address for data protection queries is info@segen.co.uk.

Segen Limited is a limited liability company incorporated in England and Wales with company number 05309114 with its registered office address at 200 Fowler Avenue, Farnborough, England, GU14 7JP.

PRIVACY POLICY FOR CUSTOMERS

Last updated: 30/04/2026

SEGEN LIMITED

PRIVACY POLICY FOR CUSTOMERS

INTRODUCTION

At Segen we take your privacy seriously and we are committed to protecting it.

This policy explains when and why we collect or receive personal information about you as our distributor, installer or other customer (or a representative of our customer), how this information is used, with whom we share that information and the rights they have over it. This policy was last updated on the date set out at the top of this page.

WHO WE ARE AND OUR ROLE

We are Segen Limited (we/us/our) and, for the purposes of UK data protection laws, we are the controller of the processing activities described below in this policy.

A controller is a person that decides why and how your personal information is processed. As the controller, we are responsible to you for the handling and treatment of that information.

Please see the section at the end of this policy for our contact and company information.

HOW WE COLLECT YOUR PERSONAL INFORMATION

We receive personal information about you that you give to us when:

  • corresponding with us by phone, email or in another way, including when making sales and aftersales related enquiries and requests;
  • placing orders for our products and making payments;
  • visiting our offices, or other premises;  and
  • interacting with us at events or in connection with promotions we run from time to time.

This information is provided by you entirely voluntarily.  If we do not receive this information, you may be unable to communicate with us effectively or unable to place orders for products with us.

We may also receive your personal information from your customers to whom you have sold our products.

THE PERSONAL INFORMATION WE PROCESS ABOUT YOU

We may process the following types of personal information about you, which we have categorised as follows:

Category of personal information

Description

Contact

information which can be used to address, send or otherwise  communicate a message to you such as your name, telephone number, address and email address.

Correspondence

information contained in our correspondence or other communications with you.

Identity

information contained in a formal identification document or other  unique reference number relating to you.

Transactional

information relating to transactions or business interactions with or involving you, including financial information


HOW WE USE YOUR PERSONAL INFORMATION

UK data protection laws require us to have a valid reason to process your personal information for each of the different purposes for which we use that information. These laws refer to each reason as a ‘lawful basis’. The purposes for which we use your personal information are explained below, together with the lawful basis under UK data protection laws on which we rely to do this.

Where you have provided consent

We may use and process your personal information where you have consented for us to do so for the following purposes:

  • in relation to any personal email address or mobile number we hold, to make electronic marketing communications including by email, SMS and, in relation to our mobile apps, push notices; and
  • any purpose we communicate to you at the time you opt-in to allow us to process your personal information.

Where processing is necessary for us to pursue our legitimate interests

We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business, for the following purposes:

Processing necessary for orders or to perform our contract with the business for whom you work

  • to enable us to receive, process and fulfil orders for our products and to perform our obligations under our contracts with you, including in relation to invoices

Processing necessary for our legitimate interests in promoting our products and services and our business

  • to contact you from time to time with marketing information where the law allows us to do so without your consent e.g. by telephone (you have the right to object to us using your personal information for this purpose at any time);

Processing necessary for our legitimate interests in to operate the administrative and technical aspects of our business efficiently and effectively

  • to verify the accuracy of information we hold about you;
  • for our internal operations, including troubleshooting, testing and statistical reporting purposes;
  • for the prevention and detection of fraud and other criminal activities;
  • to comply with a request from you in connection with the exercise of your rights where required under applicable data protection law;
  • for the purposes of a corporate restructure or reorganisation or sale of our business or assets;
  • for efficiency, accuracy or other improvements of our databases and systems e.g. by combining systems or consolidating records we or other companies in our group hold about you;
  • to maintain our or your compliance with our policies and procedures or to exercise our rights under them, including our anti-bribery, modern slavery, data protection, information security, and whistleblowing policies;
  • to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings;
  • to anonymise or pseudonymise your personal information, where appropriate, for example, to maintain the confidentiality of your communications with us; and
  • for general administration including financial planning, control and reporting and managing your queries, complaints, or claims, to send service messages and to provide you with important information about our business.

Where required to perform a contract with you or take pre-contractual steps you request

Where you are dealing with us in an individual capacity (and not on behalf of an incorporated business), we will use your personal information to fulfil orders you place with us or steps you request us to take before placing an order that require us to process your personal information.

Where required to comply with our legal obligations

We will use your personal information to comply with our legal obligations:

  • to assist any public authority or criminal investigatory body, where we are under a legal obligation to do so;
  • to identify you when you contact us where we are obliged under applicable law to do so;
  • to contact you in connection with product recalls;
  • to verify the accuracy of data we hold about you; and
  • to respond to and resolve your complaints in relation to our services where we are obliged under applicable law to do so.

OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL INFORMATION

Other companies in our group

We may share your information with other companies in our group and they may use your personal information for the purposes and ways set out in “How we use your personal information”, in connection with the services they provide, including where they complement our own services.

Our suppliers, service providers and other recipients

We may share your information with our third party service providers, agents, subcontractors and other organisations (as listed below) for the purposes of providing services to us or directly to you on our behalf.

Recipient / relationship to us

Industry sector (& sub-sector)

Accountancy and auditing services

Professional services (accountancy)

Advertising & PR agencies

Media (advertising)

Banks, payment processors and financial services providers

Financial (banking)

Cloud storage service providers

IT (cloud services)

Government tax administration offices

Government (tax)

Haulage and delivery service providers

Logistics (haulage/delivery)

Insurance services providers

Insurance (brokers/underwriting/experts)

Legal advisers

Professional services (legal services)


When we use third party service providers as our data processors, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.

When we share your personal information with third parties that are controllers of that information, they may disclose or transfer it to other organisations in accordance with their data protection policies. This does not affect any of your data subject rights as detailed below. In particular, where you ask us to rectify, erase or restrict the processing of your information, we take reasonable steps to pass this request on to any such third parties with whom we have shared your personal information.

Other ways we may share your personal information

We may share your personal information with individuals that are your customers where appropriate, for example, if they request contact information for you in relation to their orders or purchases.

We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. We may also transfer your personal information to public authorities, courts or tribunals if we are under a duty to disclose or share it in order to comply with any legal obligation, to detect, prevent or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our customers. This may involve disclosing your personal information to our customers, the police and other public authorities, criminal investigatory bodies, courts, regulators or the emergency services.  We will always take steps with the aim of ensuring that your privacy rights continue to be protected.

WHERE WE STORE YOUR PERSONAL INFORMATION

Information you provide to us may be transferred to countries outside the UK, including to companies in our group or if any of our servers or those of our third party service providers are from time to time located outside the UK. These countries may not have data protection laws similar to those of the UK and so may not protect the use of your personal information to the same standard.

If we transfer your information outside of the UK, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this policy. These steps include:

  • relying on adequacy decisions issued by the relevant UK Secretary of State where we send personal data to Andorra, Argentina, commercial organisations in Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Jersey, New Zealand, Switzerland, Uruguay, Japan, South Korea, Gibraltar or the Economic European Areas;
  • where the above does not apply, all transfers of personal data between our group companies rely on the UK International Data Transfer Agreement or Addendum issued by the Information Commissioner’s Office;
  • for transfers to US entities, relying on the EU-US Data Privacy Framework and the UK-US Data Bridge that extends that framework to the UK, where such entities are registered with the EU-US Data Privacy Framework;
  • in a limited number of circumstances, relying on binding corporate rules; and
  • ensuring that the recipients are subscribed to ‘international frameworks’ that aim to ensure adequate protection, such as the UK-US Data Bridge that extends the EU-US Data Privacy Framework to the UK.

Please contact us using the details at the end of this policy for more information about the protections that we put in place and to obtain a copy of the relevant documents.

SECURITY

We care about protecting your information. We put in place appropriate measures that are designed to prevent unauthorised or unlawful processing and accidental loss, destruction, or damage. We do this by having in place a range of appropriate technical and organisational measures, including encryption measures and disaster recovery plans.

HOW LONG WE KEEP YOUR PERSONAL INFORMATION FOR

The length of time for which we retain your personal information is determined by a number of factors including the purpose for which we use that information and our obligations under data protection and other laws in the jurisdictions that apply to us. We do not retain personal information for longer than is necessary for our processing purposes or for longer than the law otherwise permits.

We will usually retain your personal information 7 years after the date it is no longer needed by us for any of the purposes listed above under How we use your personal information. We may derogate from this retention period in the following circumstances:

  • you exercise your right to require us to retain your personal information for a period longer than our stated retention period (see further Erasing your personal information or restricting its processing);
  • you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see further Erasing your personal information or restricting its processing below);
  • we bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible; or
  • in limited cases, existing or future law or a court or regulator requires us to keep your personal information for a longer or shorter period.

AUTOMATED DECISION MAKING

We do not envisage that any decisions that have a legal or significant effect on you will be taken about you using purely automated means, however we will update this policy and inform you if this position changes.

YOUR RIGHTS

You have certain rights in relation to your personal information.  In relation to certain rights, we may ask you for further information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within one month from either the date that we have confirmed your identity or, where we do not need to do this because we already have this information, from the date we received your request.

Where the law permits, we may charge a reasonable administration fee to fulfil your rights request, or in rare cases may reject part or all of your request, where it is manifestly unfounded, or excessive (for example, in the case of repetitive or overlapping requests).

  • Accessing your personal information

You have the right to ask for a copy of the personal data that we hold about you (e.g., by emailing or writing to us at the address at the end of this policy).  Where provided for under the applicable data protection law, we may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.

  • Correcting and updating your personal information

The accuracy of your information is important to us and we are working on ways to make it easier for you to review and correct the information that we hold about you.

In the meantime, if you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, please let us know by contacting us via any of the details described at the end of this policy.

  • Withdrawing your consent

Where we rely on your consent as the legal basis for processing your personal information, as set out under “How we use your personal information”, you may withdraw your consent at any time by contacting us using the details at the end of this policy.  If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can do so, for example, using our unsubscribe tool. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.

  • Objecting to our use of your personal information

Where we rely on your legitimate business interests as the legal basis for processing your personal information for any purpose(s), as out under “How we use your personal information”, you may object to us using your personal information for these purposes, e.g., by emailing or writing to us at the address at the end of this policy. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise, we will provide you with our justification as to why we need to continue using your data.

You may object to us using your personal information for direct marketing purposes and we will automatically comply with your request. If you would like to do so, please use our unsubscribe tool.

  • Erasing your personal information or restricting its processing

In certain circumstances, you may ask for your personal information to be removed from our systems (e.g., by emailing or writing to us at the address at the end of this policy). Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request.

You may also ask us to restrict processing your personal information where you believe it is unlawful for us to continue processing, you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings.  In these situations we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings. 

  • Transferring your personal information in a structured data file ('data portability’)

Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out under “How we use your personal information”, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine-readable form, such as a CSV file.

You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.

  • Complaining to the data protection regulator

You have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the data protection regulator in the UK.  However, we encourage you to contact us before making any complaint and we will seek to resolve any issues or concerns you may have.

The contact details for the ICO are below:

Post:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Phone:

0303 123 1113

Email:

casework@ico.org.uk

CHANGES TO THIS POLICY

We may update this policy from time to time. We recommend you regularly check for changes and review all updates to this policy

CONTACT AND COMPANY INFORMATION

Please direct any queries about this policy or about the way we process your personal information to our data protection team using our contact details below.

If you wish to write to us, please write to Data Protection, Segen Limited, 200 Fowler Avenue, Farnborough, England, GU14 7JP.

Our email address for data protection queries is info@segen.co.uk.

Segen Limited is a limited liability company incorporated in England and Wales with company number 05309114 with its registered office address at 200 Fowler Avenue, Farnborough, England, GU14 7JP.