legal
Last updated: July 2026
Only those within Charged, and the sub-processors listed below, who need your data to do their job can access it — no one else.
Where we use suppliers to help deliver the Service, we restrict their use of your data to what we instruct and bind them to comply with data protection law.
Charged users must be 18 or over. If we find we've inadvertently collected data from someone under 18, we delete it as soon as we're made aware.
We are Charged Energy Ltd (referred to as "Charged," "we," "us" or "our" in this Privacy Policy), a company registered in England and Wales under company number 17277080, with our registered office at 71–75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ. Charged is the controller and responsible for your personal data. Our ICO registration reference is ZC193602.
We created Charged to make it effortless to turn everyday spending into credit against your energy bill — delivered entirely through WhatsApp, with no app to download. To provide this, we need to process your personal data, and this Privacy Policy explains how and why we do that, and what rights you have in relation to it.
This Privacy Policy sets out how and on what basis Charged collects personal data and how you and your data are protected when you use the Service via the WhatsApp Channel and/or our Website, or otherwise interact with us.
Charged cannot provide the Service without access to your personal data. If you do not want us to use your data as described here, the Service will not be for you, and we won't be able to provide it if you choose to stop sharing the data we need.
The Service is not intended for children, and we do not knowingly collect data relating to anyone under 18.
If you have any questions about this Privacy Policy or our collection, use, or storage of your personal data, please email help@getcharged.energy.
A Data Controller is a company or organisation that collects or stores personal data and decides how it is used. Charged is a data controller in respect of your personal data as described in this Policy.
A Data Processor is a company or organisation that processes personal data on behalf of a controller, acting on that controller's instructions. Where any of our sub-processors act as a controller in their own right for a specific purpose (for example, WhatsApp/Meta in respect of its own platform operation), this Policy does not govern that processing — please refer to that organisation's own privacy policy.
Personal data means any information relating to an identified or identifiable living individual — someone who can be identified, directly or indirectly, by reference to an identifier such as a name, phone number, an online identifier, or one or more factors specific to them.
We obtain your personal data when you use the Service, our Website, or otherwise interact with us. The categories we collect include:
first name, last name, and date of birth (used to confirm you're 18 or over).
your WhatsApp-registered mobile number, and email address if you provide one.
information about your linked payment card (such as card scheme, last four digits, and expiry date — we never see or store your full card number), and details of the Account you hold with us.
your Energy Provider, and the reference details needed to apply Energy Bill Credit to your Energy Account.
information about qualifying purchases made on your linked Card at participating Merchants, provided to us by our Card-Linking Provider.
the content and metadata of messages you exchange with us via the WhatsApp Channel, needed to operate the Service and respond to you.
IP address, browser type and version, device information, and similar data collected when you use our Website.
your preferences, category interests, how you interact with the Service, and your Energy Bill Credit balance and history.
your preferences in receiving marketing from us and your communication preferences.
We do not collect any special category personal data about you (such as race, ethnicity, religious beliefs, health data, or sexual orientation). It's important the personal data we hold is accurate and current — please let us know if your details change.
We collect your personal data in a few ways:
We will only use your personal data when we have a lawful basis to do so. Most commonly, this will be one of the following:
The table below sets out the main ways we use your personal data and the legal basis we rely on for each.
| Purpose | Data used | Lawful basis |
|---|---|---|
| Register and operate your Account | Identity, Contact, Energy Account Data | Performance of a contract |
| Link and monitor your Card, calculate and apply Energy Bill Credit | Financial, Transaction, Energy Account Data | Performance of a contract; consent (card linking) |
| Respond to your messages via the WhatsApp Channel | Communications, Identity, Contact Data | Performance of a contract |
| Send you Service-related notifications (e.g. credit confirmations) | Contact, Communications Data | Performance of a contract |
| Send you optional marketing | Contact, Marketing, Profile Data | Consent |
| Detect and prevent fraud or misuse | Identity, Financial, Transaction, Technical Data | Legitimate interests; legal obligation |
| Improve and troubleshoot the Service | Technical, Usage Data | Legitimate interests |
| Comply with legal, tax, and regulatory obligations | Identity, Financial, Transaction Data | Legal obligation |
Parts of the Service use automated logic and artificial intelligence. In particular:
None of this automated processing makes decisions about you that produce legal effects, or similarly significantly affect you, without the possibility of human review. If you believe an automated check has produced an incorrect result (for example, incorrectly marking your Energy Provider as unsupported), you can contact us at help@getcharged.energy for a human to review it.
Under UK data protection law, you have the right to:
To exercise any of these rights, email help@getcharged.energy. We aim to respond within one month; if your request is complex, this may take longer, and we'll keep you updated. There's usually no fee, though we may charge a reasonable fee or decline requests that are clearly unfounded, repetitive, or excessive. We may ask you to verify your identity before actioning a request.
Your personal data is processed and stored on secure systems operated by us and our sub-processors, located in both the United Kingdom/European Economic Area (EEA) and the United States. Where personal data is transferred outside the UK, we ensure appropriate safeguards are in place, which may include:
We use appropriate technical and organisational measures to protect your personal data, including encryption in transit and at rest, access controls, and regular review of our sub-processors' own security practices.
We require all third parties to respect the security of your personal data and treat it in accordance with the law. We will never sell or rent your personal data. We share your data in the following circumstances:
When you link a Card, you authorise us and our Card-Linking Provider (Fidel API Limited) to collect, process, and share your card transaction data to identify qualifying purchases and calculate Energy Bill Credit. We may not be able to provide the Service without this. You may withdraw this consent at any time by unlinking your Card, though we won't be able to continue providing the Service to you if you do.
We also work with a payment services provider (currently Modulr Finance Limited and/or its group companies) to move our own funds when applying Energy Bill Credit to Energy Accounts, as described in our Terms & Conditions.
We share your data with the technology sub-processors listed in the table below, who help us run the WhatsApp Channel, Website, and underlying infrastructure. Each is bound by contract to only use your data as we instruct and to apply appropriate data protection safeguards.
We share the minimum data needed with your Energy Provider — your account reference and the value of Energy Bill Credit being applied — to enable that credit to be applied to your Energy Account.
We may share data with regulators in connection with their duties, and with fraud prevention or law enforcement agencies where we're legally required to help them do their job.
If we sell, transfer, or merge parts of our business, the new owner may use your personal data in the same way as set out in this Policy.
| Sub-processor | Role | Data location |
|---|---|---|
| Meta (WhatsApp Business Platform) | Delivers the WhatsApp Channel through which the Service operates; processes message content and metadata | United States |
| 360dialog | WhatsApp Business Solution Provider; routes messages between our systems and the WhatsApp Business Platform | European Economic Area |
| Supabase | Database and Account storage — holds your Account, Profile, and Energy Bill Credit records | United States and European Economic Area |
| Railway | Application hosting for the systems that run the Service | United States and European Economic Area |
| Fidel API Limited | Card-linking and transaction monitoring — identifies qualifying purchases on your linked Card | United Kingdom |
| Modulr Finance Limited | Payment services provider — used to move our own funds when applying Energy Bill Credit | United Kingdom |
This list may change as we add or replace sub-processors from time to time — the current list will always be available on this page. If we make a material change to who processes your data, we'll notify you as set out in "Changes to This Policy" below.
During registration, you can choose whether to receive marketing messages from us via the WhatsApp Channel, SMS, or email. You may also receive service-related communications (such as Energy Bill Credit confirmations or Terms updates) even if you've opted out of marketing, as these are necessary to operate the Service.
You can opt out of marketing at any time by messaging us via the WhatsApp Channel, using the unsubscribe link in any marketing email or SMS, or emailing help@getcharged.energy.
We may disclose and use anonymised, aggregated statistics about use of the Service — for example, to report performance to Merchants or for our own marketing and industry analysis. Aggregated data of this kind can never be tracked back to you personally and does not constitute personal data.
We only keep your personal data for as long as reasonably necessary for the purposes we collected it for, including to satisfy legal, regulatory, tax, or accounting requirements. Depending on the type of data, this ranges from 90 days up to five years. We may keep data for longer if there's an ongoing complaint or a reasonable prospect of litigation.
When you close your Account, we anonymise and archive your personal data, which we then retain for six months to fulfil legal and regulatory requirements, unless we're required to keep it for longer.
Our Website currently uses only cookies and similar technologies that are strictly necessary for it to function — we do not currently use non-essential cookies such as analytics or advertising cookies. If this changes, we will update this section and, where required, seek your consent before setting any non-essential cookies.
If you're unhappy with how we process your personal data, please contact us first at help@getcharged.energy so we have the chance to put things right — we aim to respond within 30 days. You also have the right to complain to the UK's data protection regulator, the Information Commissioner's Office (ICO), at any time:
Information Commissioner's Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Phone: 0303 123 1113 · ico.org.uk
The Service and Website may include links to third-party websites, including Merchant websites and our Card-Linking Provider's secure card-linking pages. We don't control these websites and aren't responsible for their privacy practices. We encourage you to read the privacy policy of any website you visit via a link from our Service.
We may update this Privacy Policy from time to time. Any changes will be posted on this page and, where the change is material, we'll notify you via the WhatsApp Channel or email. Continued use of the Service after a material change constitutes acceptance of the updated Policy.