Privacy Policy

TURGON MANAGEMENT LTD

Effective Date: 12 November 2025

Last Updated: 18 November 2025


1. Data Controller Information

This Privacy Policy describes how TURGON MANAGEMENT LTD (hereinafter "we", "us", or "the Company") collects, uses, and protects your personal data when you interact with our website ecoswitchuk.com or submit information via our lead forms, including those hosted on Meta platforms (Facebook and Instagram Lead Ads).

Data Controller:
TURGON MANAGEMENT LTD
Company Registration Number: 13614887
Registered Office: 167-169 Great Portland Street, 5th Floor, London, W1W 5PF, United Kingdom

Contact for Privacy Matters:
Email: privacy@ecoswitchuk.com
Postal Address: 167-169 Great Portland Street, 5th Floor, London, W1W 5PF, United Kingdom


2. What Personal Data We Collect

We collect personal data that you voluntarily provide when you complete contact forms on our website or through Meta Lead Ads (including “Instant Forms”). This data may include:

We do not intentionally collect:

2.1 How We Collect Your Data

Your personal data may be collected through:


3. Purpose and Legal Basis for Processing

We process your personal data for the following purposes:

3.1 Lead Generation and Commercial Communication

To respond to your enquiry, provide information about solar panels, home-energy and energy-efficiency solutions, and to facilitate contact with selected commercial partners (“Sponsors”) who can offer relevant products or services (for example: solar panel installation, home-energy improvements, energy supply and related services).

Legal Basis: Your explicit consent (Article 6(1)(a) UK GDPR).

By submitting your details via our forms, you consent to:

3.2 Compliance and Audit

We retain your data for audit, legal compliance, fraud prevention and dispute resolution purposes, including maintaining records of how and when consent was obtained.

Legal Basis: Legitimate interests (Article 6(1)(f) UK GDPR) and legal obligations (Article 6(1)(c) UK GDPR).


4. How We Use and Process Your Data

Your personal data is used exclusively for the following purposes:

We do not use your data for automated decision-making or profiling in the sense of Article 22 UK GDPR.

4.1 Automated Processing & Integrations

When you submit a form on our website or via Meta Lead Ads, your data is automatically transferred via secure webhooks to our processing platform (for example, Make.com) and then stored in cloud-based systems such as protected Google Sheets (Google Workspace). These tools act as data processors on our behalf, under appropriate Data Processing Agreements (DPAs), and are used solely to route and store your data for the purposes described in this Privacy Policy.

4.2 Where Your Data Is Stored

Your personal data may be stored in:


5. Who We Share Your Data With

5.1 Commercial Partners (“Sponsors”)

Your data is shared with carefully selected third-party service providers that offer solar panel, home-energy and related efficiency services and may contact you with quotes or information relevant to your request. These entities are referred to as “Sponsors”.

A current list of Sponsors and their categories is available at: https://ecoswitchuk.com/sponsors.html. Only a limited number of Sponsors, relevant to your request and location, will receive your data. Being listed as a Sponsor does not mean that each company will necessarily contact you.

The Sponsors act as independent data controllers for their own processing activities and are responsible for providing their own privacy notices. We encourage you to review their individual privacy policies for more information on how they process your data.

5.2 Technical Service Providers (Processors)

We may use third-party technical providers who process data on our behalf and under our instructions, including:

These providers act as data processors and are bound by contractual obligations to implement appropriate security measures and to process personal data only on our documented instructions.

5.3 Legal Obligations

We may disclose your data if required by law, regulation, legal process, or governmental request, or to protect our rights, property or safety and that of our users and third parties.

Important Note: Conversion Media Srl may act solely as an advertising agency managing our Meta advertising campaigns and media budget. They do not have access to, nor process, any personal data collected through our lead forms.


6. International Data Transfers

In some cases, your personal data may be transferred to recipients located outside the United Kingdom or European Economic Area (EEA), for example where our technical providers (such as Google or ActiveProspect) host or process data on servers located in the United States or other countries.

Where such transfers occur, we ensure adequate protection by implementing:

You may request a copy of the safeguards in place by contacting us at privacy@ecoswitchuk.com.


7. Data Retention

We retain your personal data for:

After this period, your data will be securely deleted or anonymised.


8. Your Rights Under UK GDPR

You have the following rights regarding your personal data:

8.1 Right of Access

You may request a copy of the personal data we hold about you.

8.2 Right to Rectification

You may request correction of inaccurate or incomplete data.

8.3 Right to Erasure ("Right to be Forgotten")

You may request deletion of your data where there is no compelling reason for its continued processing.

8.4 Right to Restriction of Processing

You may request that we limit how we use your data in certain circumstances.

8.5 Right to Data Portability

You may request to receive your data in a structured, commonly used, and machine-readable format.

8.6 Right to Object

You may object to processing based on our legitimate interests or to any direct marketing.

8.7 Right to Withdraw Consent

Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of processing before withdrawal.

8.8 Right to Lodge a Complaint

You have the right to lodge a complaint with the UK Information Commissioner's Office (ICO):

To exercise any of these rights, please contact us at:
Email: privacy@ecoswitchuk.com
Postal Address: 167-169 Great Portland Street, 5th Floor, London, W1W 5PF, United Kingdom


9. Security Measures

We implement appropriate technical and organisational measures to protect your personal data against:

These measures include, among others, encryption in transit (HTTPS), access controls, restricted permissions on cloud-based storage (such as Google Workspace/Sheets), secure API connections, and regular security checks on our systems and integrations.


10. Cookies and Tracking Technologies

Our website uses a limited set of cookies and similar technologies, primarily for security, form protection and essential functionality. We do not currently use analytics or advertising cookies for tracking or profiling users.

10.1 Strictly Necessary & Functional Cookies

Some of our forms use Google reCAPTCHA v2 to protect against spam and automated abuse. This may set cookies and process technical information such as your IP address and browser characteristics. We also use Google Maps / Places API to help you enter your address more accurately; this may involve technical data being sent to Google.

These cookies and tools are considered strictly necessary or functional because they are essential to the security and operation of the forms.

10.2 Non-Cookie Tracking Technologies

Our forms may also include technologies that do not rely on cookies but still process technical data:

For more details on the specific cookies and technologies used, and their durations, please refer to our Cookie Policy. If our use of cookies changes in the future (for example, if we introduce analytics or marketing cookies), the Cookie Policy and, where required, the cookie banner will be updated accordingly.


11. Meta Lead Ads – Important Disclaimer

When you submit your information via a Facebook or Instagram Lead Ad form:

After submission, your data is transferred from Meta to our systems via secure integrations (for example, Make.com) and processed in accordance with this Privacy Policy. All such processing is carried out solely by TURGON MANAGEMENT LTD as the independent Data Controller.

For any questions or concerns regarding your data, please contact us directly at privacy@ecoswitchuk.com.


12. Third-Party Links

Our website may contain links to third-party websites (for example, Sponsors’ websites). We are not responsible for the privacy practices or content of such sites. We encourage you to review their privacy policies before providing any personal data.


13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies or legal requirements. The updated version will be published on this page with a revised "Last Updated" date.

We encourage you to review this policy periodically. Your continued use of our services after changes have been made constitutes acceptance of the updated policy.


14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please contact us:

TURGON MANAGEMENT LTD
Email: privacy@ecoswitchuk.com
Postal Address: 167-169 Great Portland Street, 5th Floor, London, W1W 5PF, United Kingdom