Privacy Policy

This privacy notice informs you of how and why we collect your data and what you can expect from us on data sharing, retention and protection.

Table of contents

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Last updated: November 2026

1. About this Privacy Notice

At So Energy, we take the protection of your personal information seriously.

This Privacy Notice explains how we collect, use, share, store and protect your personal information when you interact with us, use our products or services, visit our website or app, communicate with us, or otherwise have a relationship with us.

It also explains where we obtain information about you from other organisations and the rights you have under UK data protection law.

This notice applies to customers, prospective customers, former customers and other individuals whose personal information we process in connection with our products and services.

2. Who we are

So Energy Trading Limited is the controller of your personal information where we decide how and why it is used.

So Energy Trading Limited Registered in England and Wales under company number 09263295.

You can contact our Data Protection Officer at:

Email: data.protection@so.energy

Postal address: Studio 2, Power Road Studios, 114 Power Road, Chiswick, W4 5PY

You can also contact our customer service team using the contact details available on our website.

3. The information we collect about you

The personal information we collect depends on your relationship with us and the products and services you use.

Depending on your relationship with us, this may include:

Identity and contact information

This may include:

  • your name;
  • address;
  • previous address;
  • email address;
  • telephone number;
  • date of birth or age;
  • account or customer number;
  • information we use to verify your identity;
  • details about other people authorised to manage or discuss your account.

Account and energy supply information

This may include:

  • your tariff;
  • supply address;
  • Meter Point Administration Number (MPAN);
  • Meter Point Reference Number (MPRN);
  • meter details;
  • meter readings;
  • energy consumption;
  • smart meter information;
  • supply history;
  • information about switching supplier;
  • products or services you have with us;
  • information relating to solar, battery, electric vehicle or other energy-related products you use.

Financial and payment information

This may include:

  • bank and Direct Debit details;
  • payment information;
  • billing history;
  • account balance;
  • payment arrangements;
  • information about arrears and debt;
  • affordability information;
  • credit information where appropriate.

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We do not necessarily hold all payment card information ourselves. Some payments are processed on our behalf by specialist payment providers.

Credit, identity and fraud information

Where appropriate, we may process information used to:

  • confirm your identity;
  • assess creditworthiness or payment risk;
  • prevent and detect fraud;
  • determine whether additional payment arrangements, such as a deposit, may be needed;
  • locate or identify people responsible for an energy account;
  • investigate suspected fraudulent activity.

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This may include information obtained from credit reference agencies, fraud-prevention providers, tracing services and other lawful sources.

Vulnerability, accessibility and affordability information

We may process information about circumstances that affect the support you need from us, including:

  • disability;
  • health conditions;
  • accessibility requirements;
  • communication requirements;
  • financial circumstances;
  • household circumstances;
  • information relevant to the Priority Services Register;
  • other information you choose to provide about circumstances which may make you vulnerable.

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Some health and disability information is special category personal data under UK data protection law. We only process this information where we have an appropriate lawful basis and an additional legal condition permitting us to do so.

Communications and customer service information

This may include communications you have with us by:

  • telephone;
  • email;
  • webchat;
  • social media;
  • online forms;
  • complaints;
  • letters;
  • other customer service channels.

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We may record, transcribe, review and analyse communications where appropriate, including through automated technologies.

Technical and online information

When you use our website, app or online services, we may collect information such as:

  • IP address;
  • login information;
  • device information;
  • operating system;
  • browser type and version;
  • website and app usage;
  • cookie identifiers;
  • interactions with our webpages, content and advertising.

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More information about cookies and similar technologies is available through our cookie information and the Cookie Preferences tool on our website.

Marketing, profile and preference information

This may include:

  • your marketing preferences;
  • communication preferences;
  • products and tariffs you use;
  • interests;
  • survey responses and feedback;
  • interactions with our communications;
  • information showing how you interact with our website, app or advertising;
  • information we derive from other data to understand which products, services or communications may be most relevant to you.

4. Where we get your information

We collect much of your information directly from you.

For example, you may provide information when you:

  • request a quote;
  • become a customer;
  • manage your account;
  • make a payment;
  • submit a meter reading;
  • contact our customer service team;
  • make a complaint;
  • participate in a survey, promotion, referral or reward programme;
  • use our website or app;
  • apply for or use another So Energy product or service.

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We may also obtain information about you from other organisations.

These may include:

Energy industry organisations

We receive information from organisations involved in the operation of the UK energy market, including:

  • previous and new energy suppliers;
  • electricity and gas industry bodies;
  • meter operators and metering agents;
  • data collectors and aggregators;
  • smart meter infrastructure and service providers;
  • organisations responsible for industry registers and market processes.

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We use this information to supply energy, manage your meter, bill you accurately and meet our industry and regulatory obligations.

Comparison sites, affiliates and partners

If you choose So Energy through a price comparison website, switching service, affiliate, referral partner or another partner, they may provide us with information needed to provide a quote or establish your account.

Property and home-move information

We may receive information from landlords, letting agents, property-related organisations, local authorities, postal services, data providers and other lawful sources.

This can include information about:

  • a property;
  • occupancy;
  • changes in occupancy;
  • whether somebody may be moving home;
  • property identifiers such as a Unique Property Reference Number (UPRN);
  • contact information associated with a property.

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Where appropriate, we may compare this information with information we already hold to manage energy supply at a property or to identify services or communications that may be relevant to an existing or prospective customer.

Credit reference and fraud-prevention organisations

We may obtain information from credit reference agencies and fraud-prevention organisations to verify identity, assess credit or payment risk and prevent fraud.

Other people

Information may also be provided by someone acting on your behalf, a member of your household, a landlord, letting agent or another person with a legitimate connection to your account or property.

5. How and why we use your information

We only use personal information where we have a lawful reason to do so.

Our main purposes are set out below.

Purpose Examples Main lawful basis
Supplying and managing your energy Setting up your account, switching, billing, payments, meter management and customer service Contract and legal obligation
Energy industry requirements Market processes, metering, switching and regulatory reporting Legal obligation and, where appropriate, contract
Customer support Dealing with enquiries, complaints and account administration Contract and legitimate interests
Vulnerability and accessibility support PSR, reasonable support and understanding vulnerability Legal obligation and/or other appropriate lawful bases, with an additional condition where special category data is involved
Credit and payment-risk management Credit checks, payment arrangements and deposit assessments Legitimate interests and/or contract, depending on the activity
Debt management Recovering unpaid accounts, tracing and managing arrears Legitimate interests, contract and/or legal obligation
Fraud and security Identity verification, preventing fraud, securing accounts and investigating suspicious activity Legitimate interests and legal obligation where applicable
Improving our services Quality monitoring, analytics, research, customer feedback and service development Legitimate interests and consent where required
Recording and analysing communications Customer service, training, quality assurance, complaints, regulatory compliance and evidence Legitimate interests, contract and/or legal obligation
Marketing Promoting So Energy products and services Consent and/or legitimate interests where permitted by law
Personalisation and profiling Making communications and services more relevant Legitimate interests and/or consent depending on the activity
Legal and regulatory compliance Responding to regulators, courts, law enforcement and legal requirements Legal obligation and other applicable lawful bases
Establishing or defending legal claims Complaints, disputes and litigation Legitimate interests and, where necessary, legal claims conditions

Where we rely on legitimate interests

Where we rely on our legitimate interests, these may include:

  • operating and improving our energy supply and related services;
  • providing effective customer service;
  • protecting our customers, systems and business against fraud, misuse and security threats;
  • recovering money legitimately owed to us;
  • keeping appropriate records of our interactions with customers;
  • understanding how customers use our products and services;
  • improving our products, services and customer experience;
  • communicating relevant products and services to you where permitted by law; and
  • establishing, exercising or defending legal claims.

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Before relying on legitimate interests, we consider whether the processing is necessary and balance our interests against your rights, interests and reasonable expectations.

6. Vulnerability and special category information

We recognise that some customers need additional support.

You may tell us about health conditions, disabilities, accessibility requirements, financial difficulties or other circumstances so that we can understand how best to support you.

We may use this information to:

  • provide appropriate customer support;
  • offer accessible ways to communicate with us;
  • identify services or assistance that may be available;
  • determine eligibility for the Priority Services Register;
  • support customers experiencing financial difficulty;
  • fulfil our legal and regulatory responsibilities.

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Where information about your health or disability is special category data, we will only use it where an additional condition under data protection law permits us to do so.

We may also receive relevant vulnerability information from authorised energy-industry organisations and other organisations where the law permits this.

7. Credit checks, fraud prevention and identity verification

We may use your personal information to help us confirm your identity, assess credit and payment risk, prevent fraud and protect So Energy and our customers.

We may obtain and share relevant information with credit reference agencies and fraud-prevention organisations.

This may leave a record on your credit file where applicable.

Information obtained during a credit assessment may affect the payment arrangements available to you, including whether we require a deposit or another form of payment arrangement.

8. Profiling, data matching and personalisation

We sometimes combine or compare information from different sources to understand our customers and provide more relevant services and communications.

For example, we may combine:

  • information about your So Energy account;
  • products or tariffs you use;
  • energy consumption information where permitted;
  • property information;
  • home-move information;
  • interactions with our website, app or communications;
  • your marketing preferences;
  • information lawfully supplied by third-party partners.

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We may use this information to place customers into groups or segments, identify likely needs or interests, understand whether you may be moving home, or determine whether a particular product, service or communication may be relevant.

Where profiling relates to direct marketing, you have the right to object to that processing at any time.

9. Marketing and advertising

We may tell you about So Energy products, services, offers, rewards or schemes that we think may be relevant to you.

Depending on the circumstances, we may rely on your consent or our legitimate interests where electronic marketing laws allow us to do so.

We may personalise marketing using information we hold about you, such as:

  • the tariff or products you use;
  • your preferences;
  • previous interactions with us;
  • feedback;
  • relevant information about your property or circumstances;
  • information about how you interact with our website, app or communications, where this is permitted.

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We may also use advertising and marketing services to help us understand the effectiveness of our advertising, reach audiences who may be interested in our products and services, and avoid showing certain advertising where it is not relevant. This may involve matching or comparing information using identifiers such as contact details, account information or online identifiers.

Where consent is required, including under applicable rules relating to electronic marketing, cookies or similar technologies, we will obtain it.

You can opt out of direct marketing at any time. Opting out of marketing will not prevent us from sending essential communications about your energy account or services.

We may retain limited information on a suppression list after you opt out to make sure we respect your preference.

10. Smart meters and energy consumption information

If you have a smart meter that we can operate remotely, we may obtain readings from it to manage your energy supply, produce bills and meet our energy-industry obligations.

The frequency and purposes for which smart meter information can be accessed depend on applicable energy rules, your settings and, where required, your consent.

Where we want to use more detailed smart meter information for additional purposes, such as analysing your energy-use patterns to develop or recommend products and services, we will obtain consent where this is required.

You can contact us if you want further information about how your smart meter information is used.

11. Calls, chats, emails and other communications

When you communicate with us, we may record and retain information about the interaction.

Depending on the communication channel, this may include:

  • audio recordings;
  • emails;
  • webchats;
  • social media interactions;
  • customer service notes;
  • complaints;
  • transcripts of conversations.

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We may use automated technologies to produce or analyse transcripts or other information from customer interactions.

We use this information where appropriate to:

  • provide customer service;
  • keep an accurate record of interactions;
  • investigate complaints;
  • train and support our people;
  • monitor quality;
  • comply with regulatory requirements;
  • prevent or investigate fraud or security incidents;
  • improve our services.

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Automated transcripts may not always reproduce a conversation perfectly. Where we rely on information from a transcript to make a decision or take action that could affect you, we take appropriate steps to consider its accuracy and the other information available to us.

12. Debt recovery and tracing

Where money is owed to us, we may process personal information to manage and recover the debt.

This may include using or sharing information with:

  • debt collection agencies;
  • tracing organisations;
  • credit reference agencies;
  • solicitors and other professional advisers;
  • courts;
  • insolvency practitioners;
  • organisations to which a debt is legally transferred or assigned.

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We may also receive occupancy, address or contact information from lawful third-party sources where necessary to determine responsibility for an energy account or locate somebody associated with a debt.

We take particular care to ensure that information is appropriately matched before taking action against an individual.

13. Partners, referrals, rewards and other services

We work with other organisations through which customers may discover, obtain or use So Energy products and services.

These may include:

  • comparison websites;
  • switching services;
  • affiliate partners;
  • referral partners;
  • rewards and loyalty providers;
  • sales partners;
  • organisations offering products or services alongside ours.

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Where you interact with another organisation, that organisation may also be an independent data controller. You should read its privacy notice to understand how it uses your information.

If So Energy and another organisation jointly determine the purposes and means of particular processing, we will provide additional information about that joint processing where required.

14. Who we share your information with

We share personal information with other organisations where this is necessary to provide our services, operate our business, comply with our obligations or protect our legitimate interests.

Some organisations process personal information on our behalf and in accordance with our instructions. Others receive information as independent controllers and are responsible for their own use of that information.

Organisations we use may provide the following types of services:

Customer service and communications services

These help us handle telephone calls, emails, webchat and other customer interactions, administer accounts and provide customer support.

Technology, cloud and cybersecurity services

These help us host and operate our systems, store information, provide communications technology and protect our systems, services and information.

Payment and financial services

These help us process payments, manage Direct Debits and administer financial transactions.

Metering and energy industry services

These help us operate your energy supply, manage meters, obtain meter readings and participate in energy-industry processes.

Credit, identity, debt collection and fraud-prevention services

These help us verify identity, assess credit and payment risk, prevent fraud, trace customers and manage or recover outstanding balances.

Marketing, communications and analytics services

These help us manage customer communications and preferences, deliver marketing where permitted, understand how our services and communications are used and measure their effectiveness.

Research and customer insight services

These help us understand customer experiences, analyse feedback and improve our products and services.

Professional and specialist services

These include legal, audit, regulatory and other professional services that support our business.

We may also share personal information where appropriate with other energy suppliers, energy-industry organisations, landlords and letting agents, government departments, regulators, ombudsman services, law enforcement bodies, courts and other organisations where disclosure is required or permitted by law.

Where an organisation processes personal information on our behalf, we require appropriate contractual, confidentiality and security protections.

We may disclose personal information to the police, other law enforcement bodies, regulators, courts, government authorities or other organisations where we are required or permitted to do so by law.

We assess requests for personal information before making a disclosure and only disclose information where we are satisfied that there is an appropriate lawful basis.

Depending on the circumstances, a disclosure may be necessary to:

  • comply with a legal obligation;
  • prevent or detect crime;
  • protect somebody’s vital interests;
  • establish, exercise or defend legal rights;
  • support regulatory functions;
  • protect So Energy, our customers or others.

16. International transfers

So Energy is based in the UK, but some of our suppliers, service providers and partners may process or access personal information from other countries.

If personal information is transferred outside the UK, we put appropriate safeguards in place as required by UK data protection law.

Depending on the circumstances, these may include:

  • UK adequacy regulations;
  • the UK International Data Transfer Agreement;
  • the UK Addendum to the EU Standard Contractual Clauses; or
  • another legally recognised transfer mechanism.

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Where required, we assess the risks associated with international transfers and implement additional technical, organisational or contractual safeguards.

You can contact our Data Protection Officer if you would like more information about the safeguards applicable to a particular transfer.

17. How long we keep your information

We keep personal information only for as long as it is needed for the purpose for which it was collected and to meet our legal, regulatory and operational requirements.

Different types of information are kept for different periods. The following provides a general guide:

Type of information How long we generally keep it
Customer account, billing, payment and energy supply information For the duration of your relationship with us and generally for up to 6 years afterwards
Customer service communications and account records Customer service correspondence and account notes, excluding call recordings and transcripts. Generally for up to 6 years after your account closes
Call recordings and transcripts Generally for up to 2 years from the date of the interaction
Data protection rights request records Generally for up to 3 years after the request is closed
Marketing prospect and lead information Generally for up to 12 months where no customer relationship is established
Marketing preferences and opt-outs We may retain limited information for longer where necessary to ensure we continue to respect your preferences
Vulnerability and support information For as long as it is needed to provide appropriate support or meet our legal and regulatory responsibilities
Information relating to legal claims, fraud, investigations or regulatory matters For as long as reasonably necessary to manage the matter and meet our legal or regulatory obligations

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These periods may be shorter or longer where a specific legal, regulatory or contractual requirement applies, where information is required in connection with a complaint, dispute, investigation or legal claim, or where there is another lawful reason to retain it.

When personal information is no longer required, we securely delete or anonymise it in accordance with our retention and disposal requirements.

18. How we keep your information secure

We use technical and organisational measures designed to protect personal information against accidental or unlawful loss, misuse, alteration, unauthorised access or disclosure.

These measures include appropriate controls relating to:

  • access management;
  • identity verification;
  • encryption;
  • system and network security;
  • staff training;
  • supplier security;
  • monitoring and audit;
  • backup and recovery;
  • incident response.

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Access to personal information is restricted to people who need it for their work and appropriate confidentiality obligations apply.

We regularly review our security measures to ensure they remain appropriate to the nature of the information we process and the risks associated with its use.

19. Automated decision-making

We may use automated tools to assist with some aspects of our services, such as matching information, identifying patterns, assessing risk or helping us understand which communications may be relevant to particular customers.

However, not every automated process is an automated decision with a legal or similarly significant effect.

Where we make a decision about you solely through automated processing and the decision produces a legal effect or similarly significantly affects you, we will provide the information and safeguards required by data protection law, including information about your applicable rights.

20. Your data protection rights

Depending on the circumstances, you have rights over your personal information.

These include the right to:

Access your information

You can ask for a copy of the personal information we hold about you.

Correct inaccurate information

You can ask us to correct personal information that is inaccurate or complete information that is incomplete.

Ask us to delete information

In certain circumstances, you can ask us to erase your personal information.

This right does not apply where we have a legal or other valid reason to retain the information.

Restrict our use of your information

You can ask us to restrict the processing of your information in certain circumstances.

Object to processing

You can object to processing based on legitimate interests in certain circumstances.

You have an absolute right to object to the use of your personal information for direct marketing, including profiling related to direct marketing.

Data portability

In certain circumstances, you can ask us to provide information you gave us in a structured, commonly used and machine-readable format or to transfer it to another organisation.

Where we rely on your consent, you can withdraw it at any time.

Withdrawing consent will not affect processing that was lawful before you withdrew it.

Rights relating to automated decisions

You may have additional rights where a decision with a legal or similarly significant effect is made solely by automated means.

If you wish to exercise your rights, contact:

DSR@so.energy

We will normally respond within one month of receiving a valid request. In certain circumstances the law allows us to extend this period, and if this applies we will tell you.

21. Children’s personal information

Our energy supply services are not intended to be contracted by children.

We may nevertheless hold limited information about children in a household where it is relevant to providing appropriate support, understanding vulnerability, meeting regulatory obligations or providing a requested service.

Where we process this information, we will only use it where there is an appropriate lawful basis and we will take account of the particular protections that apply to children’s information.

22. Cookies and online analytics

Our website and online services use cookies and similar technologies.

Some cookies are necessary for our websites and services to operate. Others help us:

  • understand how our website and app are used;
  • remember preferences;
  • improve our services;
  • measure communications and advertising;
  • personalise content or advertising where permitted.

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Where consent is required, we will not use optional cookies unless you have agreed to them.

You can manage your choices through the Cookie Preferences tool on our website.

Further information about the cookies and similar technologies we use, including their purposes and duration, is available in our cookie information.

23. If you do not provide information

Sometimes we need personal information in order to enter into or perform our contract with you or meet a legal or regulatory requirement.

If you do not provide required information, we may not be able to:

  • create or manage your account;
  • supply a particular service;
  • process a requested payment method;
  • verify your identity;
  • meet a legal or energy-industry requirement.

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Where providing information is optional, we will make this clear where appropriate.

24. Complaints about how we use your information

If you have any concerns about how we use your personal information, please contact our Data Protection Officer first so that we can investigate.

Data Protection Officer Email: data.protection@so.energy

You have the right to complain to the Information Commissioner’s Office (ICO), the UK’s data protection regulator. You can complain to the ICO at any time, although we would appreciate the opportunity to address your concerns first.

You can find information about making a complaint on the ICO’s website.

25. Changes to this Privacy Notice

We keep this Privacy Notice under regular review.

We may update it when our products, services, technology, legal obligations or use of personal information changes.

Where we make a significant change to how we use your personal information, we will take appropriate steps to bring the change to your attention before the new processing begins where required.