Privacy Policy

Introduction

This Privacy Policy explains how Brakkn Ltd ("we", "us", "our") collects, uses, stores, and protects your personal information when you use the Energy Helper service, including our website, mobile applications, and any related services. Energy Helper is a product and trading name of BRAKKN LTD.

The Energy Helper mobile application is published by Energy Helper App Ltd, a wholly owned subsidiary of Brakkn Ltd. BRAKKN LTD is the data controller responsible for your personal data, regardless of which entity publishes the application. We are committed to protecting your privacy and handling your data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1. Information We Collect

1.1 Information You Provide

1.2 Information Collected Automatically

1.3 Information from Third Parties

1.4 Special Category Data

Special category data requires additional protection under UK GDPR Article 9. We collect one specific type of special category data, with your explicit consent:

Beyond this specific consent, we do not collect other special category data (e.g., race, religion, political views). Some general household information might indirectly reveal protected characteristics; we minimise such collection and process only what is necessary for service delivery.

1.5 Beta Programme participants

Some users access Energy Helper as beta testers — typically through an employer partnership or by direct invitation. Beta testers help us catch bugs and shape the product before it's opened to the wider public. If you are a beta tester, we process a small amount of additional information about how you use the app and any feedback you submit, on top of the data covered elsewhere in this Policy. The full detail is set out in our separate Beta Privacy Note, which you accept when you join the beta and can re-read at any time from within the app or via that link. The headline points are:

• Feedback you submit through the in-app feedback tab. When you tap the feedback tab and submit a report, we record the type of feedback (bug, suggested improvement, or other), the screen you were on, the message you write, and — if you keep the screenshot checkbox ticked — a screenshot of the screen you were on. We hold this in our database for 12 months. A copy of each report is also created in our customer support system (Freshdesk) so the team can triage it; bug reports may additionally be turned into engineering tasks in our private issue tracker (GitHub), where the same content (your message, the screen, the screenshot if attached) is visible to the engineering team. The S3 storage bucket we use as a temporary upload buffer for screenshots deletes its contents within 36 hours; the durable copy lives in Freshdesk and our database.
• Session Replay (optional, off by default). If you choose to turn this on in your privacy settings, when you submit a bug report we attach a short recording of the previous 60 seconds of your screen so we can see what was happening when you hit the problem. Form contents and any text on screen are masked — we see the layout and your clicks, not what you typed. You can turn this off again at any time. Recordings are held for 30 days. This feature is currently being rolled out; if the setting is not yet visible in the app, Session Replay is off for your account.
• Technical error telemetry. The standard Sentry-based error tracking described elsewhere in this Policy applies to beta testers in the same way as all other users — we never send your message body or screenshot to the error-tracking service.

Our lawful basis for processing feedback content and screenshots is legitimate interest — running a beta programme and improving the product based on tester feedback. Session Replay is processed only on the basis of your explicit consent, which you can withdraw at any time. You can also withdraw from the beta programme and request deletion of your beta data by emailing jon@helper.energy; the full procedure is in the Beta Privacy Note.

Beta testers are typically employees of an Energy Helper partner organisation (e.g., Big Clean Switch). Beta-tester feedback content is not shared with the partner organisation; it is used only by Energy Helper to improve the product.

2. How We Use Your Information

2.1 Purposes and Legal Bases

2.2 Consent

Where we rely on consent, you can withdraw it at any time by:

• Updating your preferences in the app
• Clicking "unsubscribe" in marketing emails
• Contacting us at my.data@helper.energy

Withdrawing consent does not affect the lawfulness of processing before withdrawal.

2.3 Legitimate Interests

Where we rely on legitimate interests, we have assessed that our interests do not unduly impact your rights and freedoms. Central to this assessment is whether you would reasonably expect us to process your data for the stated purpose. Our legitimate interests include:

• Improving and developing our services
• Understanding how customers use our service
• Conducting research and analytics to improve outcomes
• Ensuring security of our systems
• Marketing our services to existing customers

You can object to processing based on legitimate interests at any time.

3. How We Share Your Information

3.1 Service Providers (Sub-Processors)

We share data with service providers who help us deliver Energy Helper:

We do not store customer data in internal collaboration tools (e.g., Google Workspace). When we use mapping or address lookup services, we share only the minimum location data needed (e.g., postcode or coordinates) and do not include names or contact details.

3.2 Partners

If you access Energy Helper through a partner (e.g., an employer or energy supplier), we may share:

• Information on your use of the app (legitimate interests)
• Aggregated information about energy consumption (with your consent)
• Feedback you provide us about the app (anonymised unless we have your consent)

3.3 Legal Requirements

We may disclose information where required by law or to:

• Comply with legal process or government requests
• Protect our rights, privacy, safety, or property
• Enforce our terms of service
• Respond to an emergency

3.4 Business Transfers

If Brakkn is involved in a merger, acquisition, or sale of assets, your information may be transferred. We will notify you of any change in ownership or use of your personal information.

4. International Transfers

We deliberately select direct suppliers that store and process personal data only within the EU. Where those suppliers use sub-suppliers to provide their services, we require them to apply equivalent protections and to ensure their contractual arrangements provide safeguards that are equivalent to those required under UK law.

5. Data Retention

5.1 Retention Periods

5.2 Data After Account Deletion

When you delete your account:

• Personal data is deleted or anonymised within 30 calendar days of your request being approved by our team (see §6.3 below for detail on the fulfilment process)
• Anonymised/aggregated data may be retained for analytics
• Backups are purged on standard rotation (up to 90 days)

5.3 Limits on Erasure — Statutory Retention Carve-Outs

Certain records are retained beyond the 30-day fulfilment window because we are legally required to do so:

What “retained” means for these records: these records are anonymised at the point of deletion. Personal identifiers (your name, email address, and any directly identifying columns) are removed or nulled. The record itself is kept — for example, the fact that a consent was granted on a particular date, without the name of the person who granted it. This is the minimum necessary to satisfy the legal retention obligation.

If you ask us to delete your consent records, we will explain why we cannot in full. For questions, contact us at my.data@helper.energy.

6. Your Rights

Under UK GDPR, you have the following rights:

6.1 Right of Access

You can request a copy of your personal data. We will respond within one month.

How to exercise: my.data@helper.energy.

6.2 Right to Rectification

You can request correction of inaccurate or incomplete data.

How to exercise: Update your details in the app or contact us.

6.3 Right to Erasure (“Right to be Forgotten”)

You can request deletion of your data where:

• Data is no longer necessary for the purpose collected
• You withdraw consent (where consent was the legal basis)
• You object to processing and there are no overriding legitimate grounds
• Data has been unlawfully processed

How to exercise:

• In-app: Use the “Delete my account” option in the Energy Helper app (Account → Settings → Delete account). This creates a formal deletion request that is reviewed and approved by our team before fulfilment begins.
• By email: Contact us at my.data@helper.energy.

SLA: We fulfil Article 17 erasure requests within 30 calendar days of your request being received. Our team reviews and approves the request (typically within 1–3 working days); automated fulfilment across all processors then runs within that 30-day window. If fulfilment is at risk of breaching the 30-day deadline, we will contact you to explain and, if necessary, escalate to the ICO.

Limits on erasure: We may need to retain certain records for legal or regulatory reasons — see Section 5.3 above for the full list and the legal basis for each carve-out.

6.4 Right to Restrict Processing

You can request restriction of processing while we verify accuracy or assess objections.

How to exercise: my.data@helper.energy.

6.5 Right to Data Portability

You can receive your data in a structured, machine-readable format and transfer it to another provider.

How to exercise: my.data@helper.energy.

6.6 Right to Object

You can object to:

• Processing based on legitimate interests
• Direct marketing
• Processing for research/statistics

How to exercise: Email my.data@helper.energy or update marketing preferences.

6.7 Rights Related to Automated Decision-Making

We do not make decisions based solely on automated processing that produces legal or similarly significant effects. Our recommendations are informational and do not determine outcomes on their own.

6.8 How to Exercise Your Rights

• Email: my.data@helper.energy
• Post: Data Protection, BRAKKN LTD, Unit 3, Vista Place, Ingworth Road, Poole, England, BH12 1JY

We will respond within one month. If your request is complex, we may extend by two months (with notification).

We may request identification to verify your identity before processing requests.

7. Security

We use appropriate technical and organisational measures to protect your data, including encryption, access controls, multi-factor authentication for staff access, security monitoring, and incident response procedures. Staff receive security awareness training, and we review controls regularly.

8. Cookies and Tracking

8.1 What Are Cookies

Cookies are small text files stored on your device when you visit our website or use our web app.

8.2 Cookies We Use

Full cookie list: [URL TBC]

8.3 Managing Cookies

You can manage cookies through:

• Browser settings (block or delete cookies)
• Cookie settings page: [URL TBC]

Blocking essential cookies may prevent some features from working.

8.4 Do Not Track

We respect "Do Not Track" browser signals where technically feasible.

9. Children's Privacy

Energy Helper is not intended for children under 16. We do not knowingly collect data from children. If you believe we have collected data from a child, please contact us immediately.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by:

• Email notification
• In-app notification
• Prominent notice on our website

The "Last Updated" date at the top indicates when changes were made. We encourage you to review this policy periodically.

11. Complaints

If you have concerns about how we handle your data:

1. Contact us first: my.data@helper.energy
2. Escalate to the ICO: If you are not satisfied with our response, you can complain to the Information Commissioner's Office:
   • Website: ico.org.uk
   • Phone: 0303 123 1113
   • Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

We would appreciate the opportunity to address your concerns before you contact the ICO.

12. Contact Us

For privacy-related enquiries:

• Email: my.data@helper.energy
• Data Protection Contact: Jon Fletcher (CEO, DPO registered with the ICO)
• Post: Data Protection, BRAKKN LTD, Unit 3, Vista Place, Ingworth Road, Poole, England, BH12 1JY

For general enquiries:

• Email: help@helper.energy
• Website: helper.energy

Document History

This Privacy Policy was last updated in April 2026.