Privacy Notice

This Privacy Policy describes what Personal Data we collect, how we handle it, why we need it and who we share it with. We may also supplement this Privacy Policy with Data Protection Notices where appropriate.

Solar 21 Renewable Energy Limited (‘Solar 21l’) processes Personal Data and Special Categories of Personal Data to manage the offer, loan note execution, loan note servicing, loan note payment processing and to fulfil our contract with you and to comply with legal obligations. Depending on your relationship with us (e.g. as a client, a candidate for a role with Solar 21, etc.), we may collect different types of data relating to you. Further information is set out in this Privacy Policy.

Who are we?

We are Solar 21 Renewable Energy Limited (referred to as ‘Solar 21’), a limited company incorporated in Ireland and registered under company number 483963. Our registered office is at Rathcoole Premier Office Centre, Main Street, Rathcoole, Co. Dublin.

Solar 21 is a renewable energy investment company headquartered in Dublin, with locations in the UK and Italy. It specializes in the acquisition and management of solar photovoltaic (PV) installations and in the development of renewable energy projects including biomass, biogas and EFW (Energy from Waste) in the UK and Europe.

Data Protection Definitions

We use certain expressions throughout this document such as Personal Data and Special Categories of Personal Data.

Personal Data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Special Categories of Personal Data includes information revealing a person's racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

Data Controller means the entity which, by itself or jointly with others, determines the purpose and means of processing Personal Data. Solar 21 is the Data Controller in respect of Personal Data and Special Categories of Personal Data covered by this Privacy Policy.

This Privacy Policy sets out the basis on which any Personal Data and Special Categories of Personal Data we collect from you, or that you (or others) provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your Personal Data and Special Categories of Personal Data and how we will treat it.

When you become our customer, the processing of your Personal Data and, in accordance with legal requirements, Special Categories of Personal Data, will become a condition of the contract between us as we require certain information in order to be able to provide you with our investments (e.g. contact information). In those circumstances, if you do not wish us to process your Personal Data and, in accordance with legal requirements, Special Categories of Personal Data, we may be unable to provide our services to you.

If you have any queries on data protection, our Compliance Officer, Michelle Farrell may be contacted at: admin@solar21.ie or you can contact our Customer Services team on 01 458 6599.

What personal data do we collect from you?

You may give us Personal Data and Special Categories of Personal Data:

• By corresponding with us in writing, by phone, email or otherwise, we ask you to disclose only as much Personal Data and/or Special Categories of Personal Data as is necessary to provide you with details on our investments and services or to submit a question/suggestion/comment in relation to our Website, our Products or our customer service;

• By applying for, or taking out, one or more investments as a client/ loan note holder via an Independent Financial Advisor;

• By corresponding with us in relation to one or more of your investment(s) (e.g. with respect to payment of a coupon);

• By posting on our social media platforms, message boards, blogs and any other services to which you can post information. Please note that if you share Personal Data or Special Categories of Personal Data through these services, this information may become public information;

• When you supply us with goods or services;

• By applying to work with us. The type of information you may provide includes your CV, a cover letter, your name, address, email address and telephone number. CVs should include information relevant to your employment history and education (e.g. degrees obtained, places worked, positions held, relevant awards). We ask that you do not disclose Special Categories of Personal Data (e.g. nationality, gender, height, weight, medical information, religion, philosophical or political beliefs) or financial data in your application;

For all Investment available through Solar 21 we collect the following classes of Personal Data:

• Contact details (including name, address, email address and telephone number);

• Identification details (including gender, marital status, date of birth);

• Occupation details;

• PPS number;

• Nationality and country of residence;

• Photographic identification (necessary for performance of anti-money laundering checks);

• Bank details, debit/credit card details (where needed);

• Income details (where needed);

• Information relating to criminal convictions or civil litigation history, where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with this Privacy Policy. Less commonly, we may use information relating to criminal convictions or civil litigation history where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public;

• PEP (politically exposed person) status (for compliance with anti-money laundering legislation);

• In certain cases, we may receive sensitive information from which it is possible to infer your trade union membership, religious or political beliefs.

Your duty to inform us of changes It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

What personal data do we collect about you, from third parties?

We may obtain Personal Data and/or Special Categories of Personal Data about you from the following third parties:

• Other financial brokers/advisor/investment manager – as you have signed a letter of authority;

• Your legal or tax advisor;

• Your Trustee and/or Registered Administrator.

What personal data do we collect from you, about other people? We may collect Personal Data and/or Special Categories of Personal Data from you that relates to people other than the policyholder, life insured or group scheme member:

• We may collect Personal Data from you relating to trustees, beneficiaries, assignees, persons exercising a power of attorney, financial broker or advisor, investment manager, legal advisor, tax advisor, or a referee (in the event of a job application). The Personal Data collected by us with respect to such people is limited to name, address and, where relevant, identifier number, and is used only for identification purposes.

• When we receive documentary evidence from you (e.g. for the purpose of conducting anti-money laundering checks), the documentation may contain Personal Data belonging to other people, not related to your Product (e.g. a co-addressee on a bill or a partner’s name on a Marriage Certificate). The Personal Data collected by us with respect to such people is not used by us but is retained as part of your policy records. All Personal Data on these other people will be removed from our records when we execute our retention policy to remove your Personal Data from our records.

If you provide us with Personal Data or Special Categories of Personal Data relating to other people you must first: (a) inform the person about the content of this Privacy Policy; and (b) obtain any legally required consent from that person to the sharing of their Personal Data or Special Categories of Personal Data in this manner.

Why do we collect this personal data?

• We collect Personal Data and, where necessary and in accordance with legal requirements, Special Categories of Personal Data, in order to provide you with details on our investments, to transact business, to develop or enhance our service and to recruit staff.

We will use this information:

• To manage the offer, loan note execution, loan note servicing, loan note payment processing and to fulfil our contract with you and to comply with legal obligations.

• To communicate with you as part of our business relationship with you so that we can fulfil our contract with you;

• To communicate with your Financial Advisor as part of our business relationship with you and in order to help us fulfil our contract with you;

• To create a candidate profile for you if you are a prospective employee so that we can take steps prior to entering into a contract with you;

• As part of our efforts to keep our Websites safe and secure which is necessary for compliance with our legal obligations and to help us fulfil our contracts;

• To administer and improve our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, which is necessary for our legitimate business interest. For further information please see our Cookie Policy;

• For training and security purposes which is necessary for compliance with our legal obligations and for our legitimate business interest;

• To assess whether to provide insurance and the level of premium to be paid which is necessary for compliance with our legal obligations and to help us fulfil our contract with you;

• To process your investment premium and other payments;

• To make suggestions and recommendations to you and other users of our Website about services that may interest you. This is necessary for our legitimate business interests and may be based on your consent where you have chosen to give it;

• To deliver information about our investments and services to you or to enter you in promotional competitions, where you have subscribed to same and in accordance with your preferences and based on your consent where you have chosen to give it;

• To prevent, detect and investigate crimes, including fraud and money laundering;

• To carry out research and analysis including analysis of our policyholders and others whose Personal Data we collect as set out in this Privacy Policy;

• To establish and defend legal rights, to protect our operations or those of our Group companies or business partners;

To comply with regulatory requirement, the legal basis for the processing of your Personal Data and Special Categories of Personal Data are:

• Processing necessary for the performance of a contract which you have entered into or to take steps at your request prior to entering into a contract;

• Processing necessary for the purposes of the legitimate interests which we pursue prior to contract and post contract (for further details, see the section entitled WHO MIGHT WE SHARE YOUR PERSONAL DATA WITH?) where such interests are not overridden by your interests or fundamental rights or freedoms which require the protection of your information;

• Processing based on your consent which we obtained from you when you made your investment, for example, if necessary in order to process a Special Category of Personal Data;

• Processing necessary for compliance with a legal obligation to which we are subject; and

• Processing that you have provided consent for with respect to processing for one or more specific purposes (e.g. subscribing to a mailing list, entering a competition, submitting a request for information or communication).

Who might we share your personal data with?

In certain instances, we may make your information available to third parties with whom we have a relationship where that third party is providing services on our behalf. We will only provide those third parties with information that is necessary for them to perform the services and we take measures to protect your information.

The information we collect may be used, stored and processed in the EU, UK, United States. Switzerland, Ireland or in any other country in which Solar 21 does business. By providing the information via the website, you are consenting to the transfer of the information outside of your country to any country (including countries which may not have adequate levels of protection).

Solar 21 may disclose information it has collected about you on the website if required to do so by law or when necessary to protect the rights of Solar 21 or its employees.

If you hold insurance against a liability that may be incurred by you against a third party, where for whatever reason you cannot be found or you become insolvent, or the court finds it just and equitable to so order, then your rights under the contract will be transferred to and vest in the third party even though they are not a party to the contract of insurance. The third party has a right to recover from the insurer the amount of any loss suffered by them. Where the third party reasonably believes that you as policyholder have incurred a liability the third party will be entitled to seek and obtain information from the insurer or from any other person who is able to provide it concerning:

• the existence of the insurance contract,

• who the insurer is,

• the terms of the contract, and

• whether the insurer has informed the insured person that the insurer intends to refuse liability under the contract.

How long do we keep hold of your personal data and special categories of personal data?

The time periods for which we retain your Personal Data and Special Categories of Personal Data depends on the type of information and the purposes for which we use it. We will keep your information for no longer than is required or permitted.

All Personal Data and Special Categories of Personal Data will be retained for the duration of the periods set out in our Data Retention Policy. These periods of time are subject to legal, tax and regulatory requirements or to enable us to manage our business.

If you would like further information, please contact us at the details provided below.

In some circumstances we may anonymise your Personal Data and Special Categories of Personal Data so that it can no longer be associated with you, in which case we may use such information without further notice to you. This anonymised data may be used for research or analytical purposes.

Do we transfer your information outside the European Union or European Economic Area?

If we transfer personal data to a third party or outside the EU we as the data controller will ensure the recipient (processor or another controller) has provided the appropriate safeguards and on condition that enforceable data subject rights and effective legal remedies for you the data subject are available.

What are your rights with respect to your personal data and special categories of personal data?

You have the following rights:

• To access the Personal Data and Special Categories of Personal Data we hold about you.

• To require us to rectify any inaccurate Personal Data or Special Categories of Personal Data relating to you without undue delay.

• To have us erase any Personal Data or Special Categories of Personal Data we hold about you in specific circumstances, e.g. where it is no longer necessary for us to hold the Personal Data or Special Categories of Personal Data for the administration of your contract or if you have withdrawn your consent to the processing.

• To object to us processing your Personal Data or Special Categories of Personal Data in specific circumstances, e.g. processing for profiling or direct marketing.

• To ask us to provide your Personal Data and Special Categories of Personal Data to you in a portable format or, where technically feasible, for us to port that information to another provider provided it does not result in a disclosure of information relating to other people.

• To request a restriction of the processing of your Personal Data or Special Categories of Personal Data.

• In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Data or Special Categories of Personal Data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. In that instance, any processing that we have carried out before you withdrew your consent remains lawful.

You may exercise any of the above rights by writing to us at our registered office : Compliance Officer, Solar 21, Rathcoole Premier Office Centre, Main Street, Rathcoole, Co Dublin, or by emailing us at admin@solar21.ie

In the above circumstances, we may need to request specific information from you to help us confirm your identity and ensure your right to access the Personal Data or Special Categories of Personal Data (or to exercise any of your other rights). This is another appropriate security measure to ensure that Personal Data or Special Categories of Personal Data is not disclosed to any person who has no right to receive it.

You may lodge a complaint with respect to our processing of your information directly with the Supervisory Authority, the Office of the Data Protection Commission with an address at Canal House, Station Road, Portarlington, Co. Laois.

Data security

We have put in place measures to protect the security of your Personal Data and Special Categories of Personal Data.

Details of these measures are available upon request.

Third parties will only process your Personal Data and Special Categories of Personal Data on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your Personal Data and Special Categories of Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data and Special Categories of Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data and Special Categories of Personal Data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

What will happen if we change our privacy policy?

This Privacy Policy may change from time to time, and any changes will be posted on our Website and will be effective when posted. Please review this Privacy Policy each time you use our Website or our services. The date this Privacy Policy was last updated is shown below.

How can you contact us about data protection?

You can contact us:

By phone: Customer Services team on 01 458 6599 By email:admin@solar21.ie

By post addressed to: Compliance Officer, Solar 21 Renewable Energy Limited t/a Solar 21, Rathcoole Premier Office Centre, Main Street, Rathcoole, Co Dublin.

September 2020

Rathcoole Premier Office Centre
Main Street, Rathcoole, Co Dublin, Ireland.
T: +353 (0)1 458 65 99
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Solar 21 Renewable Energy Limited T/A Solar 21. Registered in Ireland Number 483963. Registered Address Rathcoole Premier Office Centre, Main St Rathcoole, Co. Dublin. Directors: Michael Bradley (MD), Sandra Donovan.