Privacy Policy

Introduction

This privacy policy explains how Lighthouse Green Fuels Limited (LGF) and Alfanar Energy Limited (AEL) (referred to collectively as we, us, or our) collect and process your personal data, in connection with LGF’s application for a Development Consent Order (DCO) for a new waste to sustainable aviation fuel facility (Facility) and in connection with LGF’s other reporting and consultation obligations in relation to the proposed development of the Facility.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

 

About Lighthouse Green Fuels Limited and Alfanar Energy Limited

Lighthouse Green Fuels Limited (company number 10773515 with registered office at 1 Cornhill, London, England, EC3V 3NR) and Alfanar Energy Limited (company number 11520080 with registered office at The Argyll Club, 1 Cornhill, London, United Kingdom, EC3V 3ND) are joint controllers responsible for your personal data. This means that we may jointly determine why and how your personal data is processed and that we are jointly responsible to you under the law for that processing.

We do not perform all processing of your personal data as joint controllers. Both LGF and AEL might make decisions regarding certain processing of your personal data independently of the other.

This policy sets out how we process your personal data as joint controllers, and the arrangements that have been agreed between LGF and AEL to process and protect your personal data in compliance with the law. If you have any questions about the policy or how we use your personal data, please contact Katerina Hrebenarova using the following details:

Post: Lighthouse Green Fuels Ltd, 1 Cornhill, London, EC3V 3NR

Email: Katerina.Hrebenarova@alfanar.com

 

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Some personal data is known as ‘special category data’. This includes data about a person’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, data concerning health, a person’s sex life or their sexual orientation, and biometric data. We would not normally expect to process special category data.

We may collect your personal data in various contexts before, during and after the DCO application process and when you use our website.

 

1. Public Consultations

• We will be carrying out public consultations about our proposals for the Facility.
• We will collect your data in the course of a consultation if you submit a consultation response, or if someone else submits a consultation response that includes information about you.

  What data we collect

• • The data we collect through consultations is any data included in the responses. Usually this will include your name, address, and contact details as well as views on the questions asked in the consultation.

  Purpose and legal basis for processing

• • We use the consultation data to analyse the views of people who respond to the consultation, to develop changes to our proposals where appropriate, to inform our submissions to the Planning Inspectorate, and to inform our communications strategy. In some instances we are under a statutory obligation to consult certain stakeholders and in that case we will use the consultation data to help us fulfil those statutory obligations as well. Our consultation documents will make clear if the consultation is a statutory consultation.
  • The legal basis we rely on to process the consultation data is Article 6(1)(f) of the UK GDPR, which allows us to process personal data when this is necessary for the purposes of our legitimate interests, except where those interests are overridden by the interests of the individuals whose data we are using. Our legitimate interest is to further the development of the Facility project by gathering and understanding the views of stakeholders.
  • In the case of a statutory consultation the legal basis we rely on to process the consultation data is Article 6(1)(c) of the UK GDPR, which allows us to process personal data where this is necessary for the purposes of complying with our legal obligations.
  • We do not expect that your consultation responses will include any special category data. 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 by including it in your submission you have explicitly consented to us processing it for those purposes.

  Who we share the data with

• • We may share the consultation data with our professional advisors and / or contractors so that they can assist us in administering and analysing the consultation and provide advice to us concerning the consultation and the development of the Facility.
  • We may also share the consultation data with the Planning Inspectorate so that the Planning Inspectorate can take it into account when considering our DCO application.
  • Our use of the data may include publishing analyses of the consultation responses.

 

2. Land Referencing

• When preparing the DCO application and at various stages during and after the application process we have to complete a process called land referencing. This means that we have to gather information about people who have an interest in land that is affected by the development proposed in the DCO application.
• We collect land referencing information from publicly accessible sources, such as HM Land Registry records, and by circulating questionnaires. We may collect your data from your responses to a land referencing questionnaire or from a response provided by somebody else. For example, if you are a tenant your landlord’s questionnaire response might include information about your tenancy.

  What data we collect

• • The personal data that we may collect for land referencing includes your name, address, and other contact details and information about the nature and value of your interests in the relevant land. For instance, we may collect data about whether you are a freeholder or leaseholder of the relevant land, and the duration of your interest in the land. We may also collect data about how your interest in the relevant land could be affected by the proposed development, for example if your access to the land might be interrupted.

  Purpose and legal basis for processing

• • We will use the land referencing data to prepare the Book of Reference, and to keep it up-to-date. The Book of Reference is a document we are required to submit to the Planning Inspectorate and keep up to date as part of the DCO application process. The Book of Reference includes information about people whose interests in land are likely to be affected by the proposed development.
  • We will also use the land referencing data to identify people who we are under a statutory obligation to consult and to notify of developments in the DCO application process. We will use the contact details in the land referencing data to issue consultation documents and notices to those people.
  • We will use the land referencing data to inform our proposals and designs for the Facility development and for the purpose of our submissions to the Planning Inspectorate.
  • We will use the land referencing data for the purposes of negotiations with people whose interests in land are affected by the proposed development, and for the purpose of exercising compulsory acquisition powers or temporary possession powers as appropriate if the DCO is granted. We will also use it to respond to legal challenges and claims.
  • The legal basis we rely on to process the consultation data is Article 6(1)(f) of the UK GDPR, which allows us to process personal data when this is necessary for the purposes of our legitimate interests, except where those interests are overridden by the interests of the individuals whose data we are using. Our legitimate interest is to promote the development of the Facility.
  • In the case of land referencing data that the law requires us to collect and use the legal basis we rely on is Article 6(1)(c), which allows us to process personal data where this is necessary for the purposes of complying with our legal obligations.

  Who we share the data with

• • We may share the land referencing data with our professional advisors and or contractors so that they can assist us in preparing the Book of Reference and in issuing consultation documents and notices, and so that they can provide advice to us concerning the development of the Facility, the DCO application process, exercising powers under the DCO (if it is granted), and responding to legal challenges and claims.
  • We may also share the land referencing data with the Planning Inspectorate so that the Planning Inspectorate can take it into account when considering our DCO application.
  • Where we use the land referencing data to send notices about the DCO application we will share it with contractors involved in printing and delivering those notices, so that they can produce the notices and deliver them to the correct recipients.
  • We are required to publish the Book of Reference.

 

3. Examination Process

• The DCO application is being considered in a public process known as the examination. The examination is carried out by the Planning Inspectorate. Before and during the examination people are able to make submissions to the Planning Inspectorate either in person at examination hearings or in writing. Submissions made in writing are published by the Planning Inspectorate on its website.
• We collect submissions published on the Planning Inspectorate website. Those submissions may include what are known as ‘relevant representations’, ‘written representations’, ‘statements of common ground’, and answers to written questions posed by the Planning Inspectorate. We also take notes of submissions made at examination hearings.

  What data we collect

• • We collect all of the personal data that is included in submissions published on the Planning Inspectorate website or made at examination hearings. The nature of this personal data varies depending on the nature of the submission, but often includes names, information about interests in land, and views about the proposed Facility development and its impacts.

  Purpose and legal basis for processing

• • We will use data collected for the examination in order to inform our own submissions to the Planning Inspectorate, to answer questions raised in those submissions or by the Planning Inspectorate, for the purpose of negotiating with stakeholders, for the purposes of responding to legal challenges or claims, and for the purposes of meeting our legal obligations in relation to the DCO application process.
  • The legal basis we rely on to process the examination data is Article 6(1)(f) of the UK GDPR, which allows us to process personal data when this is necessary for the purposes of our legitimate interests, except where those interests are overridden by the interests of the individuals whose data we are using. Our legitimate interest is to promote the Facility development effectively during and after the examination.
  • In the case of examination data that the law requires us to collect and use the legal basis we rely on is Article 6(1)(c), which allows us to process personal data where this is necessary for the purposes of complying with our legal obligations.
  • We do not expect that the examination data will include special category data, but if it does the condition we rely on to process it under Article 9 of the UK GDPR is that by including the data in submissions that you knew would be published on the Planning Inspectorate website or at a public examination hearing you have manifestly made the data public.

  Who we share the data with

• • We may share the examination data with our professional advisors and / or contractors so that they can assist and advise us in connection with the above purposes.

 

 4. Correspondence

• We may engage in correspondence with you before, during, or after the DCO application process, for example if you contact us to request copies of DCO documents.

  What data we collect

• • We collect any personal data that you include in your correspondence with us. The nature of that data depends on what you choose to disclose to us, but will generally include contact details such as your name and address so that we can respond to you.

  Purpose and legal basis for processing

• • We will use the data collected from your correspondence to answer your enquiries. For example, if you request copies of DCO documents that you are entitled to receive we will use your data to provide those documents to you. We may also use your data to respond to legal challenges or claims that you make.
  • The legal basis we rely on to process the consultation and engagement data is Article 6(1)(f) of the UK GDPR, which allows us to process personal data when this is necessary for the purposes of our legitimate interests, except where those interests are overridden by the interests of the individuals whose data we are using. Our legitimate interest is to promote the Facility development effectively before, during and after the consultation and engagement.
  • We do not expect that you will provide us with special category data, but if you do the conditions we rely on to process it under Article 9 of the UK GDPR is that by providing it to us you have explicitly consented to use processing it for the purpose of responding you your enquiry, or that our processing is necessary for the establishment, exercise, or defence of legal claims.

  Who we share the data with

• • We may share the consultation and engagement data with our professional advisors and / or contractors so that they can assist and advise us in connection with your correspondence.
  • If we use contractors to respond to your requests we may share your data with those contractors so that they can provide the response. For example, if you request copies of documents we may use a courier service to deliver the documents to you and will share your delivery address details with them so that they can do so.

 

5. Negotiations

• We engage in negotiations with people affected by the proposed Facility development, for instance to acquire land from them or to agree common approaches to aspects of the development that impact them.

  What data we collect

• • If we are negotiating with you we collect any personal data that you or your representatives provide to us in the course of those negotiations. This personal data often includes information about the nature and value of your interests in land, information about the financial effects on you of the proposed development, and information about your business (if the development affects your business).

  Purpose and legal basis for processing

• • We will use the data for the purpose of conducting our negotiations with you. We may also use the information to respond to legal challenges or claims that you make, to inform any negotiations that we are conducting with other people, and to inform our submissions to the Planning Inspectorate.
  • The legal basis we rely on to process the consultation and engagement data is Article 6(1)(f) of the UK GDPR, which allows us to process personal data when this is necessary for the purposes of our legitimate interests, except where those interests are overridden by the interests of the individuals whose data we are using. Our legitimate interest is to further the development of the Facility project.

  Who we share the data with

• • We may share the information with our professional advisors and /or contractors so that they can assist and advise us in connection with the above purposes.
  • We will not share the information with the Planning Inspectorate or other interested parties if the information was explicitly provided on a confidential or ‘without prejudice’ basis. If the information was not explicitly provided on that basis we may share it with the Planning Inspectorate or other interested third parties.

 

6. Newsletter Subscriptions

• From time to time, we may publish an email newsletter that you can subscribe to via our website.

  What data we collect

• • If you subscribe to a newsletter of ours, we will collect your first name, last name, your email address, and the date that you subscribe. If you later unsubscribe we will delete the data from our systems.

  Purpose and legal basis for processing

• • We will use this data for the purpose of sending you our newsletter if you subscribe to it.
  • When processing the data in this way we rely on Article 6(1)(a) of the UK GDPR, which allows us to process your personal data where you have given your consent for us to process it for a particular purpose. By subscribing to the newsletter you consent to us processing your data for the purposes of sending it to you. You can withdraw your consent at any time.

  Who we share the data with

• • We may share this data with the contractors who deliver our email newsletter for us.

 

7. Our Website

• We may collect and use your personal data in other ways when you visit and use our website.

  What data we collect

• • When you browse our website, we may collect:
    • Technical Data: including internet protocol (IP) address browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
    • Usage Data: including information about how you interact with and use our website.
  • We may also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.
  • As you interact with our website, we may automatically collect Technical Data and Usage about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
  • We use your Technical Data to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). The legal basis we rely on to process Technical Data for this purpose is Article 6(1)(f) of the UK GDPR, which allows us to process personal data when this is necessary for the purposes of our legitimate interests, except where those interests are overridden by the interests of the individuals whose data we are using. Our legitimate interest is in the running our business, network security and to prevent fraud. Occasionally, we might be obliged to collect Technical Data to comply with a legal obligations under Article 6(1)(c).
  • We use Technical Data and Usage Data to deliver relevant website content to you. The legal basis we rely on to process Technical Data and Usage Data for this purpose is Article 6(1)(f) of the UK GDPR, which allows us to process personal data when this is necessary for the purposes of our legitimate interests, except where those interests are overridden by the interests of the individuals whose data we are using. Our legitimate interest is to study how customers use our website, to keep our website updated and relevant, to develop our business.
  • We may share Technical Data and Usage Data with our website developers so that they can assist and advise us in connection with the above purposes.
  • We may share Technical Data and Usage Data with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

 

8. International transfers

• We may sometimes transfer your personal data to countries outside the United Kingdom. Whenever we do this we will make sure that we do it in compliance with data protection law. This means that: (a). we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data further to Article 45 of the UK GDPR; or (b). if we transfer your personal data to a country not covered by an adequacy regulation, we will put in place appropriate safeguards as required under Article 46(2) of the UK GDPR.
• At the moment, the only time we transfer data outside the UK is to make use of the data hosting services provided by our cloud storage provider. That hosting service is provided from Europe so is covered by an adequacy regulation.
• Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

 

9. Data security

• We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
• We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
• All of our professional advisors and contractors are bound by legal obligations to keep the personal data confidential, so it remains confidential when we share it with them.

 

10. Data retention

• We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
• To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
• In most instances we will need to retain data until the DCO application has been decided and the challenge period has passed. If the DCO is granted we will need to keep information relevant to the implementation of the DCO during the construction period for the authorised works and for as long as there is any prospect of claims for compensation.

 

11. Third party links from this website

• This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

 

 

12. Changes to this policy

• We keep our privacy policy under regular review. This version was last updated on 28 February 2024. Historic versions can be obtained by contacting us using the contact details above.
• It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

13. Complaints

• You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK’s regulator for data protection issues (ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

14. Your rights

  You have the right to:

• • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • If you want us to establish the data’s accuracy.
    • Where our use of the data is unlawful but you do not want us to erase it.
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.