Privacy Policy - Komparly

Privacy Policy

1. Introduction and General Terms

This Consumer Privacy Policy covers the processing of personal data by ProminentContact LTD, trading as Komparly, a private limited company under the laws of England and Wales with company number 12150394, whose registered office is at Lily Hill House, Lily Hill Road, Bracknell, England, RG12 2SJ and ICO Registration Number ZA599278 (“Komparly”, “we”, “us”, or “our” in this policy).

This policy applies specifically to personal data collected from consumers, individuals acting in a personal or household capacity, in connection with our consumer lead generation and energy comparison activities. It is a separate and standalone policy from Komparly’s platform privacy policy, which covers our data platform and database services.

If you have any questions about this policy or how we handle your personal data, please contact us at:

We are committed to protecting your privacy and processing your data lawfully, fairly, and transparently in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 (DPA 2018), the Privacy and Electronic Communications Regulations 2003 (PECR), and all relevant ICO guidance.

This policy explains:

  • What personal data we collect from you;
  • Why and how we use it;
  • Who we share it with;
  • How long we keep it; and
  • Your rights and how to exercise them.

2. What Personal Data We Collect

When you submit an enquiry through one of our consumer-facing campaign pages or comparison websites, we collect the following categories of personal data:

Information you provide directly:

  • Full name
  • Home address and postcode
  • Personal telephone number (mobile and/or landline)
  • Personal email address
  • Confirmation that you are aged 18 or over
  • Current energy supplier, tariff type, and payment method (e.g. prepayment meter, direct debit)
  • Any other information you choose to provide in your enquiry
  • Date of birth validation is implemented within our forms and we carry out checks to ensure individuals are aged 18 or over. Records identified as underage are automatically excluded prior to data sharing

Information collected automatically at point of submission:

  • IP address
  • Date and timestamp of submission
  • Form version and consent wording displayed at time of submission
  • Device type and browser information

The automatically collected information is retained as auditable evidence of your consent and is not used for any other purpose.

We collect all consumer data directly from you via our website forms and do not obtain consumer personal data from third-party sources for these services.

You are responsible for ensuring that the information you provide is accurate and up to date.

3. Lawful Basis for Processing

We process your personal data on the following lawful bases under UK GDPR:

Consent (Article 6(1)(a)):

Consent is our primary lawful basis for processing and sharing your personal data with marketing partners for the purpose of contacting you about home energy deals and related consumer products. We obtain your consent through an active, affirmative submission on our consumer campaign pages. No boxes are pre-ticked. You may withdraw your consent at any time -see Section 8 for how to do this.

Legal Obligation (Article 6(1)(c)):

We may process your data where we are required to do so by law, for example in response to a lawful request from the Information Commissioner’s Office (ICO) or another regulatory authority.

Legitimate Interests (Article 6(1)(f)):

We may process limited data under legitimate interests for fraud prevention, system security, and the maintenance of our suppression and opt-out records. We only rely on this basis where our interests are not overridden by your rights and freedoms.

All electronic marketing communications are carried out in compliance with the Privacy and Electronic Communications Regulations (PECR).

In summary, we rely on the following lawful bases for specific processing activities:

  • Consent – for collecting your enquiry details and sharing them with partners for marketing purposes
  • Legitimate Interests – for fraud prevention, data validation (including HLR/LLR checks), and maintaining suppression records
  • Legal Obligation – for compliance with regulatory and legal requirements

4. Your Consent - What You Are Agreeing To

ProminentContact LTD (t/a Komparly) is the data controller responsible for collecting and sharing your personal data as described below.

By clicking “Get Quote”, you confirm that you have read the Privacy Policy and consent to be contacted for marketing purposes by the following organisations in relation to your enquiry:

  • ResQ LTD
  • British Gas / Centrica
  • EDF Energy
  • E.ON / E.ON Next
  • Scottish Power
  • Octopus Energy
  • OVO Energy

You can choose how you would like to be contacted:

Telephone
SMS
Email
Post

You may withdraw your consent at any time.

Organisations you consent to may contact you more than once in relation to your enquiry.

Your consent satisfies all requirements under UK GDPR and ICO guidance, in that it is:

  • Freely given - Your enquiry is processed on the basis of your consent to be contacted by the organisations listed above in relation to relevant energy offers;
  • Specific - it names the types of contact and categories of partner who may contact you;
  • Informed - this policy sets out in full how your data will be used;
  • Unambiguous - you must take a positive action (click) to submit;
  • Granular - Consent is collected separately for each communication channel
  • Withdrawable - you can withdraw at any time with no detriment.

4A. Data Protection Impact Assessments

We carry out Data Protection Impact Assessments (DPIAs) where our processing activities are likely to result in a high risk to individuals’ rights and freedoms, including consumer data collection and sharing for marketing purposes. These assessments ensure that appropriate safeguards are implemented.

5. How We Use Your Personal Data

We use the personal data you provide for the following purposes:

  • To process your home energy enquiry and match you with relevant product offers from our partner network;
  • To pass your details to ResQ LTD and their energy supplier clients so they can contact you directly about competitive energy deals and related products;
  • To carry out data quality and validation checks prior to passing your data to partners;
  • To conduct screening checks appropriate to the type of data and channel used, as described in Section 6;
  • To record and retain evidence of your consent for audit and regulatory compliance purposes;
  • To process your opt-out or data deletion requests promptly and update our suppression records;
  • To comply with our legal and regulatory obligations, including responding to ICO or law enforcement requests where required.

We do not use your consumer data to build sales intelligence databases, conduct commercial profiling for third parties, or for any purpose unrelated to the consumer energy services described in this policy.

We do not carry out automated decision-making or profiling that produces legal or similarly significant effects on individuals.

We do not sell your personal data to third parties.

6. Who We Share Your Data With

ResQ LTD and Their Energy Supplier Clients:

Your personal data is shared with ResQ LTD (1st Floor 1 Paragon Square, Hull, East Yorkshire, England, HU1 3JZ), who act as an independent data controller and may contact you directly by telephone, email, SMS, or post regarding home energy switching deals and related products offered by their partner energy suppliers, based on your consent.

We enter into formal data sharing agreements with all partners who receive consumer data. These agreements define the roles and responsibilities of each party, ensure compliance with UK GDPR and PECR, and require appropriate technical and organisational safeguards.

We conduct due diligence on all partners before sharing data, including assessing their data protection practices, regulatory standing, and complaint history.

Once your data is shared, each organisation acts as an independent data controller and is responsible for its own processing of your personal data.

ResQ’s energy supplier clients who may include the following energy suppliers relevant to your enquiry:

  • British Gas / Centrica
  • EDF Energy
  • Scottish Power
  • E.ON / E.ON Next
  • Octopus Energy
  • OVO Energy

The table below lists the key third parties who may receive your personal data in connection with your consumer enquiry:

Only the organisations listed in Section 4 will receive your personal data based on your consent.

Organisation / Partner Role Privacy Policy
ResQ LTD Contact centre partner for home energy campaigns View Policy
British Gas / Centrica Energy supplier client (via ResQ) View Policy
EDF Energy Energy supplier client (via ResQ) View Policy
Scottish Power Energy supplier client (via ResQ) View Policy
E.ON / E.ON Next Energy supplier client (via ResQ) View Policy
Octopus Energy Energy supplier client (via ResQ) View Policy
OVO Energy Energy supplier client (via ResQ) View Policy

Each third party listed above operates under its own privacy policy and acts as an independent data controller in respect of your data once received. We strongly recommend that you review their respective privacy policies using the links provided.

Data Quality and Suppression Screening:

Prior to passing your data to telephony partners, we carry out appropriate screening to protect consumer rights. The type of screening applied depends on how and when your data was collected:

  • PPC and live enquiry leads (HLR / LLR screening): For leads generated through paid search or live digital campaigns, we carry out HLR (Home Location Register) and LLR (Local Location Register) checks to validate that telephone numbers are active and reachable. This ensures only valid, live contact numbers are passed to our partners.

These validation checks may be carried out using trusted third-party providers under strict contractual controls and data protection obligations.

  • Historic or list-based data (TPS screening): Where previously collected data from earlier consumer enquiries is processed, we screen telephone numbers against the Telephone Preference Service (TPS) and Mobile Preference Service (MPS) registers before passing to any telephony partner. Numbers registered with TPS/MPS will not be called for unsolicited marketing unless specific consent to be contacted has been obtained from the individual.

These checks are carried out under our legitimate interests in ensuring data accuracy and reducing invalid contact attempts. They do not involve profiling or automated decision-making and have no legal or significant effect on individuals.

In all cases, we only pass data to telephony partners where we have a valid consent record and have taken appropriate steps to verify the data quality.

Technology and Infrastructure Providers:

We use trusted technology partners for data storage, hosting, and platform infrastructure. All such providers are bound by data processing agreements and are only permitted to process your data in accordance with our documented instructions and applicable data protection law. Your data is stored within the UK and EEA.

Government Authorities and Regulators:

We may disclose your personal data to government bodies, law enforcement agencies, or the ICO where required by law or in connection with legal proceedings.

Business Transfers:

In the event of a merger, acquisition, or sale of assets, you will be informed of any change in ownership and provided with any choices available to you in respect of your personal data.

7. How Long We Retain Your Data

We retain your personal data for as long as is necessary for the purposes for which it was collected, in line with the following periods:

  • Active consumer enquiry data: retained for a maximum of 24 months from the date of your consent, or until you withdraw consent – whichever is sooner. This retention period is based on typical customer decision cycles and partner engagement timelines.
  • Consent audit records: the record of your consent (including IP address, timestamp, and exact wording shown) is retained for a minimum of 6 years in line with UK statutory obligations, to enable us to respond to any regulatory or legal enquiry regarding the lawfulness of processing.
  • Suppression records: if you opt out or withdraw consent, your details are added to our internal suppression list and retained for as long as necessary to ensure that you are not contacted again, subject to periodic review in line with data protection requirements.
  • Subject Access Request (SAR) logs: retained for a minimum of 6 years.

To determine the appropriate retention period in each case, we consider the sensitivity of the data, the purposes for which it is processed, and applicable legal requirements.

8. Your Rights Under UK GDPR

You have the following rights in relation to the personal data we hold about you. We will respond to all valid requests within one calendar month, free of charge.

  • Right of Access - you may request a copy of all personal data we hold about you (a Subject Access Request or SAR).
  • Right to Rectification - you may ask us to correct inaccurate or incomplete data.
  • Right to Erasure - you may ask us to delete your personal data where there is no longer a lawful basis for us to hold it.
  • Right to Restriction - you may ask us to restrict how we use your data in certain circumstances.
  • Right to Object - you may object to processing based on legitimate interests or for direct marketing at any time. Where you object to direct marketing, we will stop processing your personal data for this purpose immediately.
  • Right to Withdraw Consent - you may withdraw your marketing consent at any time with no detriment to you. Withdrawal does not affect the lawfulness of processing before withdrawal.
  • Right to Data Portability - you may request your data in a structured, machine-readable format.
  • Right to Proof of Consent - you may request a copy of your consent record (date, time, IP address, and exact wording shown at submission). We will provide this within 5 business days.
  • Right to Suppression - you may request that your details are added to our suppression list and excluded from all future marketing activity. This will be actioned within 48 hours.
  • Right to Complain - if you are unhappy with how we handle your data, you have the right to complain to the Information Commissioner’s Office (ICO) at ico.org.uk or by calling 0303 123 1113.

We aim to acknowledge and respond to complaints within 5 business days.

To protect your personal data and prevent unauthorised disclosures, we may require reasonable proof of identity before responding to a rights request.

9. How to Opt Out or Withdraw Consent

You can stop receiving marketing communications or request deletion of your data at any time using any of the following methods:

  • Email: compliance@prominentcontact.com
  • Telephone: (+44) 3338 980 725
  • Unsubscribe link: click the unsubscribe link in any email or SMS you receive from us.
  • Post: ProminentContact LTD (t/a Komparly), Lily Hill House, Lily Hill Road, Bracknell, England, RG12 2SJ

Where you request deletion, we will remove your data from active systems. We may retain minimal information (such as your email address or telephone number) on a suppression list to ensure you are not contacted again.

All opt-out and data deletion requests will be processed within 48 hours. Once processed, your details will be added to our internal suppression list and will not be passed to any further marketing partner. We will confirm your suppression in writing upon request.

This suppression record will only contain the minimum data necessary (such as your email address and/or telephone number) to ensure you are not contacted again.

You may also register with the Telephone Preference Service (TPS) at www.tpsonline.org.uk to opt out of all unsolicited telephone marketing. Please note that TPS registration applies to list-based and historic data. If you have provided specific consent to be contacted, that consent takes precedence in respect of that contact only.

10. How We Protect Your Data

We are committed to ensuring the security of your personal data. We implement appropriate technical and organisational measures to guard against unauthorised access, alteration, disclosure, or destruction of your information. Our security measures include:

  • SSL/TLS encryption for all data in transit;
  • Secure servers located within the UK and EEA;
  • Role-based access controls, restricting access to authorised personnel only;
  • Regular review of information collection, storage, and processing practices;
  • Data pseudonymisation where technically feasible; and
  • Internal data protection and security policies for all staff;
  • Regular security testing, including vulnerability assessments and penetration testing;
  • Continuous monitoring and logging of system activity;
  • Incident response procedures for managing potential data breaches;

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the ICO and, where required, you as the data subject, without undue delay and in accordance with UK GDPR Article 33. We operate in line with internationally recognised security standards, including ISO 27001-aligned controls and SOC 2 security principles.

11. Children

Our consumer services are available to individuals aged 18 and over only. We do not knowingly collect or process personal data from individuals under the age of 18.

Our consumer enquiry forms include a self-declaration checkbox requiring users to confirm that they are aged 18 or over at the point of submission.

We do not carry out technical age verification; however, if we become aware that personal data has been submitted by an individual under the age of 18, we will delete such data from our systems without undue delay and in any event within 72 hours.

If you believe a person under 18 has submitted data through our services, please contact us immediately at compliance@prominentcontact.com.

12. Cookies

Our consumer-facing websites use cookies and similar tracking technologies to record form submissions, measure campaign performance, and improve user experience. We use cookies and similar technologies in accordance with PECR. Where required, we obtain your consent through a cookie banner before placing non-essential cookies on your device. You can manage your preferences at any time.

We use Google Analytics to collect pseudonymised usage data. You can opt out of Google Analytics tracking at https://tools.google.com/dlpage/gaoptout.

This may involve data being processed on servers located outside the UK or EEA, subject to appropriate safeguards.

13. International Data Transfers

Your personal data is stored and processed within the United Kingdom and the European Economic Area (EEA).

Where limited processing by trusted service providers involves access from outside the UK or EEA, we ensure that appropriate safeguards are in place in accordance with UK GDPR. These safeguards include the use of the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses.

We ensure that any such transfers are subject to appropriate risk assessments and contractual protections to safeguard your personal data.

If you would like further information about any international data transfers, please contact us at compliance@prominentcontact.com.

14. Changes to This Policy

We review and update this Consumer Privacy Policy regularly to ensure it remains accurate and compliant with applicable law. Any material changes that affect how we use your personal data will be communicated to you by email or by a prominent notice on our website. The current version of this policy is always available at https://www.komparly.com/privacy-policy

Version: 1.1
Last Updated: March 2026
Next Review: Annually or upon regulatory change

15. How to Contact Us

For any questions, data rights requests, or complaints about this policy or the way we handle your personal data, please contact us:

  • Email: compliance@prominentcontact.com
  • Telephone: (+44) 3338 980 725
  • Post: Data Protection, ProminentContact LTD (t/a Komparly), Lily Hill House, Lily Hill Road, Bracknell, England, RG12 2SJ

If you are not satisfied with our response, you have the right to complain to the Information Commissioner’s Office:

  • Website: ico.org.uk
  • Telephone: 0303 123 1113
  • Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

We cooperate fully with regulatory authorities and comply with all applicable data protection laws and guidance.