Privacy policy

Who we are

Network Nation Limited is a company registered in England and Wales, with its registered office at 124-128 City Road, London EC1V 2NX, United Kingdom.

Network Nation Limited owns several subsidiaries, including:

MyUnit Limited (registered in England and Wales, company number 14720878)
GXNN Sunrise Utilities Services Limited (registered in the Republic of Kenya, company number PVT-DM1ZP76R)
Network Nation Nigeria Limited (registered in the Federal Republic of Nigeria, company number 9712217)

Together, these are referred to as the “Network Nation group.” The Network Nation group provides software and services to manage meter reading, billing, payments, and reconciliations for electricity, water, heat, and gas.

Our customers (the organisations that buy our software and services) are responsible for operating utility networks. We call our customers utility network managers, and they include landlords of a range of property types, landlords’ appointed agents (managing agents, property managers, facilities managers), land owners, and private utility companies. Individuals employed by or acting on behalf of a utility network manager may use our browser based applications to administer and operate their utility networks.

We also provide software to individuals and companies who occupy property units managed, serviced, or owned by our customers, and who pay our customers for utility services. We call these our “end users,” and they use one of our native apps or a browser based web app to see consumption, bills, and make payment.

We also have several websites for promotional purposes.

Personal information: when we decide, and when your utility network manager decides

Data protection law distinguishes between the organisation that decides why and how personal information is used (the controller) and the organisation that handles it on the controller’s instructions (the processor). Which one we are depends on the information.

We are the data controller for any data submitted to us through our websites or by email directly to us - for example, if you contact us, apply for a job, or subscribe to updates.
Your utility network manager is the data controller for any information (including personal information) we hold about you as a user of our software and services. We act as a data processor on their behalf, handling that information to deliver the services they have bought from us, and we do not use it for our own purposes.

To exercise a right over your utility account, see Section 12. In most cases you should contact your utility network manager first, since they are the controller. If you contact us instead please route your query as follows:

in the UK, email support@myunit.tech
in Nigeria, email support@networknation.ng
in Kenya, email connect@sunriseutilities.com

Data we collect

Identity

Our customers (utility network managers) provide us with the name, email address, and phone number of end users and of their own staff or those working on their behalf.

For end users, we also receive the address of the property unit you occupy, your occupancy type (e.g. tenant or owner), your role on the account (e.g. primary or additional account holder), and the dates of your occupancy.

In the UK, our customers will also use our software and services to tell us whether end users meet the criteria for the Priority Services Register (PSR), and why - see Section 4.

Account set up data

Our customers provide the credit limit applied to each end user account, the credit control process on the account, the tariffs used to calculate bills, and the bank account details where they wish to receive funds we collect on their behalf.

For end users migrating from a service provider historically appointed by our customer, we may be provided with identity and account set up data from the departing service provider, including personal information. In this scenario, the previous service provider was a data processor, and your utility network manager is the data controller, prescribing why and how personal information is migrated from the old service provider to us.

For individuals employed by or acting on behalf of a utility network manager, we also receive permissions data, which determines which features and functionality are available to that person in our applications.

Metering and consumption data

We process readings taken from smart meters and sensors installed at your property or property unit, for billing and utility service management. Meter readings tell us the quality of the energy, gas, water, heat and HVAC and how much was used at a supply point and when.

Billing and account data

We calculate and store billing amounts, a history of amounts owed and paid, and the payment method used.

Payments

We use third party payment service providers (“PSPs”) to collect and refund money from end users. This involves us capturing dates and amounts of payment, and a selected payment method from end users. When a payment is made, the payer is sharing their payment details directly with our PSPs, in accordance with the PSP’s privacy policy and terms. We only receive confirmation that a payment was made, the amount, and a reference. Payment information is collected directly by our PSPs inside their own secure components; your card and account details never reach our servers and we cannot see them.

Our PSPs are Stripe (UK) and Paystack (Nigeria).

Communications

We store messages you send us (support, feedback, or complaints) and our replies, so we can respond and keep a record of what was agreed.

Device and technical data

We collect the device type, operating system, app or browser version, IP address, sign in events, and crash/diagnostic and server logs of the requests made, for our websites, browser apps, and native apps. If you have push notifications enabled, we also hold a push notification token issued by Apple’s or Google’s notification service for your device. We use this data to keep the service running, investigate faults, detect abuse, and deliver notifications.

Website visitors

If you complete our contact form, we record this data with your IP address and browser user agent, so we can respond and limit automated abuse of the form. If you accept analytics cookies, we also receive the usage measurements described in Section 8.

We do not knowingly collect more data than is needed to provide the services we commit to our customers.

Priority Services Register (PSR) and other vulnerability data

In the UK, our customers may confirm whether an end user meets the criteria for the Priority Services Register (PSR) - for example, because of a disability, chronic illness, or age-related vulnerability that means additional support may be needed (such as advance notice of a planned supply interruption).

This is a special category of sensitive personal data. Some points specific to it:

We collect this data from the utility network manager, who is the data controller responsible for deciding when and why to collect it, and for having a regulated and lawful basis to do so. We do not collect this data directly from end users.
We process it to meet the required Ofgem regulation and to identify appropriate support for end users who meet the criteria for the PSR. Access to it is restricted to those who need it for that purpose.
It is subject to additional security and access controls beyond our standard measures (Section 14).

This section 4 does not currently apply outside the UK.

If you have questions about where this information is held about you, or why, or wish to have it corrected, contact your utility network manager in the first instance.

Why we use it, and our legal bases

To provide the service our customers have contracted - we read and display meter data, create and maintain accounts, calculate and display bills and charges, process payments, and maintain the applications needed to meet our contractual obligations to our customers. This is necessary to perform the contract between you and your utility network manager, and the contract between them and us.
To keep the service secure and reliable - authenticating sign ins, investigating faults, preventing fraud and abuse. This is in our and our customers’ legitimate interests in running a service that is safe to use.
To meet legal obligations - billing, accounting, tax, and regulatory record keeping.
To answer you - responding to an enquiry you send us, in our legitimate interest in dealing with people who contact us.
To understand how our websites and applications are used - with analytics, and only where consent is required and has been given (Section 8).
Priority Services Register data - processed on the legal basis set by Ofgem regulation.

Automated decisions

Decisions about connecting, disconnecting, or reconnecting your utility supply may be made solely by automated means, based on factors such as your payment or account status, without a person reviewing the decision before it takes effect.

Because this can significantly affect you, you have the right to:

ask for a person to review the decision;
explain your circumstances and ask for it to be reconsidered; and
contest the decision.

To exercise this right, contact your utility network manager. In the UK, email support@myunit.tech. In Nigeria, email support@networknation.ng.

If you are on your utility network manager’s Priority Services Register (Section 4), this is taken into account by our automated disconnection process before any action is taken, in line with Ofgem’s vulnerability regulation.

What the My Utility Manager app does and does not do

My Utility Manager is a companion to your utility account.

No advertising or tracking - the app contains no advertising software, no third party advertising identifier, and does not track you across other companies’ apps or websites. We do not sell personal information or share it with data brokers.
No location, contacts, photos, or health data - the app never asks for and cannot read any of these.
Camera - the payment component can optionally scan a payment card. This happens only if you choose it; the image is processed on your device by the payment provider’s software and is never sent to us. The rest of the app does not use the camera.
Your sign in session - is held in the device’s own protected storage (iOS keychain or Android keystore) so you don’t have to sign in every time. Signing out deletes it.
Exports - when you export data (such as a statement), the file is created on your device and goes nowhere else unless you choose to share it.
Push notifications - the app sends notifications for things you need to know about your account (for example, a new bill or a supply interruption). These are not marketing or promotional, and we do not currently offer a separate in-app opt-out for them since every notification serves an operational purpose. You can turn off notifications for the app at any time in your device’s settings. To deliver these, we hold a push notification token issued by Apple’s or Google’s notification service for your device (see Section 3).

The app is delivered and updated through the Apple App Store, Google Play, and the Expo update service, each of which collects its own installation and delivery information under its own privacy policy, which we do not control.

Cookies and analytics

Our websites and our browser based applications use a small number of essential cookies needed to store your login status; these are always set.

We also use Google Analytics on our websites and browser based applications to measure how many people visit and which pages they read. These cookies are set only if consent is given via the banner shown on first visit; you can change your mind at any time using the “Cookie settings” link in the footer, and rejecting analytics clears the cookies already set and stops further measurement.

The My Utility Manager app (used by end users) contains no analytics or advertising cookies.

Where information is held

Our platform runs in Amazon Web Services data centres in London, United Kingdom. Because our group includes entities in Nigeria and Kenya, and some providers listed in Section 9 operate internationally, information may also be handled outside the country you live in, including in the European Economic Area and the United States, and may flow between our UK platform and our Nigerian and Kenyan operations.

Where information leaves the United Kingdom or the European Economic Area, we rely on an adequacy decision covering the destination country (a government finding that the destination’s data protection law is equivalent), or on standard contractual clauses with the UK’s International Data Transfer Addendum, so that it keeps an equivalent level of protection.

Where information is transferred to or from Nigeria or Kenya, we rely on contractual safeguards between Network Nation group entities, and with our service providers, that impose data protection obligations equivalent to the Nigeria Data Protection Act 2023 and the Kenya Data Protection Act 2019. Neither the Nigeria Data Protection Commission nor Kenya’s Office of the Data Protection Commissioner currently maintains a country adequacy finding covering the United Kingdom, so we do not rely on adequacy for these transfers.

You can ask us for details of the safeguards that apply to any specific transfer.

How long we keep it

Account, metering, and billing information (including credentials for accessing our applications, for end users or our customers) is kept for as long as our customer requires, which is normally the latest of: (1) the termination of the utility supply requirement, (2) the time required for our customer to settle the account, or (3) the time required for our customer to meet its own legal duties. We may keep anonymised metering and account balance information for the purposes of trend analysis and product development.

Financial records are typically kept for seven years after the end of the relevant tax year, as accounting and tax law requires. Financial records in our ledger are, by design, never edited or deleted - a mistake is corrected by posting an equal and opposite entry, so the history of what was charged and paid stays intact and auditable. That is a requirement of sound accounting rather than an exception to your rights, and it does not stop us correcting or removing personal details attached to those records.

Contact form submissions are kept for up to two years. Analytics data is retained by Google Analytics for up to fourteen months. Server and security logs are normally kept for no more than ninety days, unless needed for an ongoing investigation.

Your rights

Depending on where you live, you generally have the right to:

ask what information is held about you and get a copy of it;
have inaccurate information corrected;
ask for information to be deleted, where there is no overriding reason to keep it;
ask us to restrict how information is used, or object to a particular use;
receive information you gave us in a portable, machine-readable form;
withdraw consent at any time, where we relied on consent; and
complain to a data protection regulator.

To exercise a right over your utility account, contact your utility network manager, who is the controller of that information. If you contact us instead please route your query as follows:

in the UK, email support@myunit.tech
in Nigeria, email support@networknation.ng
in Kenya, email connect@sunriseutilities.com

For anything we control ourselves, such as a website enquiry, write to us directly (Section 17). We will respond within one month, and tell you if we need longer.

You can complain to your national regulator:

United Kingdom - Information Commissioner’s Office, ico.org.uk
Nigeria - Nigeria Data Protection Commission, ndpc.gov.ng
Kenya - Office of the Data Protection Commissioner, odpc.go.ke

Closing your account and deleting the app

Your login is created for you by your utility network manager, so they close it. Ask them to close your access, or email us and we will arrange it with them.

Signing out of the app removes the stored session from your device; deleting the app removes everything it holds locally. Neither deletes records held on the platform, since your utility network manager may still need them to settle your account - the retention rules in Section 11 apply to those.

How we protect it

Traffic between your device and our platform is encrypted in transit, and information is encrypted at rest in our databases. Staff access is limited to those who need it to run and support the service. Passwords are held by our sign in provider and are not visible to us; card details are held by our payment providers and are not visible to us either. PSR and other vulnerability data (Section 4) is subject to additional access restrictions.

No system can be guaranteed secure, but if a breach is likely to affect you, we will act on it and notify you and the relevant regulator(s) where the law requires it - including, where applicable, within 72 hours to the NDPC or ODPC.

Children

Our services are intended for adults who hold or help manage a utility account. They are not directed at children, and we do not knowingly collect personal information from anyone under 18. If you believe a child’s information has reached us, tell us and we will remove it.

Changes to this policy

We update this policy as the platform changes. The date at the top shows when it last changed. If a change materially affects how your information is used, we will give notice through the app, the web application, or by email before it takes effect.

Contact us

Network Nation Limited, 124-128 City Road, London EC1V 2NX, United Kingdom.

Email: hello@networknation.tech

Data Protection Officer: Jennifer Viccars, jennifer@networknation.tech