3. How we collect your data

This policy contains important information about what to expect when we collect personal data via all platforms, including when you visit our website, when you subscribe to our marketing communications or when you contact us for any other reason. It further explains the specific ways in which we use and disclose that information.

3.1 Information you provide to us directly

This privacy notice applies to the information we collect in regard to:

• Persons that subscribe to our communications; i.e. marketing emails, online feedback forms (1), newsletters and event notifications;

• Persons that provide information to the project through feedback and enquiries, including in-person at consultation events; and

• Persons that complete a Land Interest Questionnaire.

(1) Online feedback forms from the statutory consultation for the Development Consent Order application for the Project is gathered using the Typeform platform and Typeform’s privacy policies also apply. Please click here if you wish to view Typeform’s privacy policies.

3.2 Marketing communications

When you subscribe to our newsletter, we may collect limited personal data from you:

• Name and job title (where applicable);

• Email address and telephone number;

• Company name where applicable.

4. Information that we may obtain from third party sources

4.1 We may receive personal data about you from third parties in connection with the development and operation of our Project, for instance we may receive information about property,  property owners/occupiers and/or persons with other property interests from land agents and/or solicitors.

4.2 We may also engage land referencing agents in order to obtain any land related rights required in order to develop the Project.  They may contact you on our behalf about the Project and enquire about any such rights or obligations you may have.  They will then put you in contact with us to discuss the Project and share your details with us. We may also receive information from local councils, other statutory undertakers and public bodies when reviewing such rights.

4.3 We may also collect some of your information from other third parties, including public records such as the Land Registry, Companies House, the electoral roll, Experian 192, the Charity Commission, the Financial Conduct Authority, TraceIQ, BT Directory, online registries, websites of organisation and information which may be obtained from a general internet search or from other persons with a legal or beneficial interest in the land. Please note that we may combine personal data we receive from other sources with personal data you give us and personal data we collect about you.

5. How we store, process and share your data

5.1 It is necessary to collect and use personal data in order to comply with our legal obligations under the Planning Act 2008 and associated regulations. We have a legitimate interest to use the personal data we collect to further engage with you in connection with the Project.

5.2 We will only use your personal data for the purpose for which we collect it, which may include the following:

• Carrying out enquiries into land ownership and occupation, and land values / compensation.

• Communicating with you about the Project, including to conduct negotiations.

• Surveying land that may be affected by the Project.

• Consulting on the Project and reporting to the Secretary of State, Planning Inspectorate or local authorities on the consultation. This may involve passing your personal data to those parties, and in some cases, we are required to publish the data as part of a consenting process.

• The Planning Inspectorate’s privacy notice can be viewed here: https://www.gov.uk/government/publications/planning-inspectorate-privacy-notices/customer-privacy-notice

• Future development and implementation of the Project.

• To fulfil a contract, or take steps linked to a contract: this is relevant where you make an enquiry about leasing, selling or agreeing any other rights and/or obligations with respect to land that you own or occupy, such rights being in relation to the Project, or where you wish to become an investor. This may include:

- verifying your identity;

- communicating with you;

- arranging the lease and payment;

- managing the lease and access to the land.

• As required by the Project Entity to conduct our business and pursue our legitimate interests, in particular this may include:

- Using your information to deliver the Project and investor relations programme, and responding to any comments or complaints you may send us;

- monitoring the use of our websites, and using your information to help us monitor, improve and protect the Project, investor relations programme and websites, both online and offline;

- using information you provide to personalise our website for you;

- using information you provide to investigate any complaints received from you or from others, about our website, investor relations programme or the delivery of the Project;

- for business transfers: we may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us in connection with our service is among the assets transferred; and

- using data in connection with: offering to obtain land related rights, legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation).

• Where you give us consent, in particular this may include:

- sending you direct marketing in relation to the Project, including investor materials;

- placing cookies and use similar technologies in accordance with the below section ‘Information about our use of cookies’ and the information provided to you when those technologies are used; and

- on other occasions where we ask you for consent, using the data for the purpose which we explain at that time.

• For purposes which are required by law, this may include:

- in response to requests by government or law enforcement authorities conducting an investigation.

• To exercise compulsory acquisition powers in the event that an order has been made under the Planning Act 2008 and only from the date such an order comes into force, this may include:

- where the applicable order authorises the Project Entity to construct, operate, maintain and/or decommission the Project, we may process additional personal data about you in connection with such order, including the exercising of compulsory acquisition powers. Whilst the Project Entity has sought to acquire the necessary land, interests or rights for the Project by agreement, there may be a number of interests that may need to be compulsorily acquired in order for the Project to be delivered. As a part of the compulsory acquisition process, the law requires the Project Entity to request that those people and organisations with a legal or beneficial interest in land which might be subject to compulsory acquisition powers provide us with information in order for us to establish whether they are entitled to claim compensation;

- where it is necessary for us to collect and use your personal data in order to comply with our legal obligations under the order, Planning Act 2008, the Compulsory Purchase Act 1965 and the Compulsory Purchase (Vesting Declarations) Act 1981 in relation to the exercise of compulsory acquisition powers. This is the basis on which our processing of your personal data is lawful;

- to contact you to discuss the acquisition of land or rights over land from you and any compensation payable to you;

- to produce documents that are required by law including a General Vesting Declaration, which will be registered at the Land Registry and which will be a publicly available document;

- to notify you of the making of a General Vesting Declaration;

- to serve a Notice to Treat and Notice of Entry on you; and

- if applicable, share your mortgage reference with lenders or mortgagees to enable them to check information which may affect them;

• We also have a legitimate interest to use the personal data we collect to engage further with you in connection with the Project and these interests are not overridden by any detriment to your rights or freedoms. This is also the basis on which our processing of your personal data is lawful.

5.3 We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out later in this notice. Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.

5.4 We will only use your personal data for the purpose for which it is collected, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

5.5 In general, whilst we will not proactively collect sensitive or special category personal data about you and we do not expect that your consultation responses will include any special category data, in limited circumstances there may be reasons for processing such data, such as when you engage with us during the consultation process and voluntarily provide us with information relating to your health and medical conditions. It is completely optional for you to provide such information when engaging with us. We may use any special category data you provide us with to manage our relationship with you or for the purposes of undertaking any environmental or equality impact assessments relating to the Project.

5.6 Stricter conditions apply to the processing of special category data, and we only process such data if these conditions are satisfied. With respect to the special category data processed, we will only process such information where you provide us with your explicit consent or where such processing is necessary for the purposes of carrying out our legal and regulatory obligations. If your response does include special category data, the condition we rely on to process it under Article 9 of the UK GDPR is that it is retained for purposes of substantial public interest as we are required by Regulation 5(2)(5) of the Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009 to retain responses to consultations and provide them to the Secretary of State on request.

6. Who we may share this data with, where and when?

6.1 We may share your personal data with our parent company (Island Green Power Limited) and our professional advisers including communications consultants, environmental consultants, land agents and land referencers and our legal advisors . We may also share your information (where required or permitted by law) with government bodies and law enforcement agencies.

6.2 Additionally, in the event that the business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.

6.3 We will not rent or sell your information to third-parties  without your consent.

7. How we store information and International transfers

7.1 In general, the personal data that we collect from you will be stored at a destination within the UK or European Economic Area (EEA). However, we may also transfer your data outside the UK or EEA, if stored on external platforms.

7.2 Please note that some countries outside of the UK or EEA have a lower standard of protection for personal data, including lower security requirements and fewer rights for individuals. Where your personal data is transferred, stored and/or otherwise processed outside the UK or EEA, we will take all reasonable steps to ensure that your personal data is treated securely and in accordance with this policy. When personal data is transferred internationally to a country that is not deemed adequate by the European Commission or the UK Secretary of State, we will rely on acceptable and defined legal mechanisms such as using standard contractual clauses which have been approved by the European Commission or the UK Government.

8. Data security

8.1 We take care to ensure the security of your personal data in use, storage and transmission and that it is only accessed by verified persons who have the necessary authority. All of our personnel who have access to personal data are legally and contractually obliged to respect the confidentiality of this information and we deliver training to ensure this is maintained.

8.2 We have in place appropriate policies, rules and technical and organisational measures to protect your personal data from unauthorised or unlawful processing, and against accidental loss, destruction or damage.

9. Cookies information

9.1 Our website uses cookies to help provide you with the most convenient browsing experience we can. Cookies are small text files that are placed on your computer or mobile phone when you browse websites. They are not executable and are harmless to your computer.

9.2 We use cookies to compile visitor statistics such as how many people have visited our website, what type of technology they are using (e.g. PC or Mobile Phone), what pages are being looked at, etc. All this useful information helps us to continuously improve our website and visitor experience.

9.3 If the settings on your internet browser that you are using to view this website are adjusted to accept cookies, we take this, and your continued use of our website, to mean that you accept their use.

9.4 Should you wish to remove, or not use cookies from our site, virtually all modern browsers allow you to see what cookies are held your browser and to delete them if you wish. Many browsers can also be set up to ask consent for each individual cookie.

9.5 This gives you very fine control over what cookies you allow on your browser. Most browsers also give you the right to block any third-party cookies. It is also possible to tell your browser to block all cookies from being set. You can access your cookie set-up in the settings of your browser.

10. Use of third-party cookies

10.1 We may use external services such as Google Analytics, Facebook, LinkedIn and X to display certain content on our Website.

10.2 We may use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics sets a number of cookies in order to evaluate your use of our site and enable us to carry out actions including (but not limited to):

• Tracking the number of visitors to our Website;

• Monitoring the number of users on our Website at any given time; and

• Analysing popular content on our Website;

• Analytics information

10.3 As mentioned, we may use external services such as Google Analytics, Facebook, LinkedIn and X to display certain content on our website. We cannot prevent such websites from collecting information about your usage of their services, for example: the number of plays of a video, how many visits to the website and accessing location data, etc.

10.4 Google will use this information for the purpose of evaluating your use of our websites, compiling reports on website activity for Website operators and providing other services relating to Website activity and internet usage. Google may also transfer this information to third-parties where required to do so by law, or where such third-parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.

11. Location data

11.1 When you access the  website by, or through a mobile device, we may access, collect, monitor and/or remotely store “location data,” which may include GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your device. Location data may convey to us information about how you browse and use the website. Some features of the website, particularly location-based services, may not function properly if use or availability of location data is impaired or disabled.

12. Retention of personal data

12.1 We will retain your personal data only for as long as we need it for the purposes set out in this notice, except in circumstances where we need to retain it for longer to comply with legal obligations or to progress legal claims. At the end of the retention period, we will take steps to delete your personal data or hold it in a form that no longer identifies you.

13. What rights you have

13.1 You have a number of rights under the Data Protection Legislation in relation to the way we process your personal data, which are set out below. You may contact us using the details at the end of this privacy notice to exercise any of these rights.

13.2 You have the following rights: