ETHICAL ELECTRIC PRIVACY POLICY Last Revised: December 15, 2015 This policy ("Policy") covers the privacy practices that Ethical Electric, Inc. ("Ethical Electric", "we" or "us") employs with respect to information we collect (i) when providing renewable energy electric supply service (the "Electric Supply Service") to our customers ("you" or "your"), and (ii) when you use www.ethicalelectric.com and other Ethical Electric Web and mobile sites which display this Policy (the "Sites") (collectively, our Electric Supply Service and Sites shall be referenced herein as the "Services"). We encourage you to review this Policy from time to time to make sure that you understand how any Personal Information we collect will be used. This Policy is applicable to all of our customers and users of our Services. By using our Electric Supply Service (including by signing up to receive the Utility Services) or accessing our Sites, you agree to be bound by this Policy. If you do not agree to the terms of this Policy, please do not use any of our Services. Each time you use our Services, the current version of the Policy will apply. We reserve the right to change the provisions of this Policy at any time. We will alert you that changes have been made by indicating on the Policy the date it was last updated. Accordingly, we encourage you to frequently check the date of the Policy (which appears at the top) and review any changes since the last version. You acknowledge that this Policy is part of our Terms of Service https://ethicalelectric.blob.core.windows.net/web/documents/termsofservice.pdf, which is incorporated by reference, and by accessing or using our Services, you agree to be bound by the Terms of Service. If you have any questions about our privacy practices, please refer to the end of this Policy for information about how to contact us. A. What Is Personal Information? As used herein, the term "Personal Information" means information that specifically identifies an individual (such as a name, address, telephone number, mobile number, e-mail address, utility account number or credit card number) and information about that individual or his or her activities that is directly linked to personally identifiable information. Ethical Electric s Policy in no way restricts or limits our collection and use of aggregate information. In some instances, we may combine other information with Personal Information. If we combine other information with Personal Information, we will treat the combined information as Personal Information. B. What Personal Information Do We Collect? 1. Active Collection Personal Information may be collected in a number of ways when you use our Electric Supply Service or visit our Sites. We collect certain information you voluntarily provide to us, such as when you enroll as a customer, create an account or a profile, send us an email or
sign up to receive email or text message updates, fill out a form, connect through a social feed, sign up to be a volunteer or host an event, request information or apply for a job or internship. Such information may include Personal Information, such as your name, mailing address, email address, phone number, and credit card information. Personal Information and demographic information may also be collected if you provide such information in connection with creating a profile or group, leaving comments, posting blog comments or other content, sending an email or message to another user, or participating in any interactive forums or features that we offer through our Services. In addition, from time to time we may collect demographic, contact or other Personal Information you provide in connection with your participation in surveys, contests, games, promotions, and other activities. 2. Passive Collection When you use the Services, some information is also automatically collected. We treat this information as Personal Information if we combine it with or link it to any of the Personal Information. Otherwise, the information collected is used in the aggregate only. a. Sites When you use the Sites we may collect your Internet Protocol (IP) address, your operating system, the browser type, the address of a referring web site, and your activity on our Sites. We may also automatically collect certain information through the use of "cookies" or web beacons. Cookies are small data files stored on your hard drive at the request of a website. Among other things, cookies help us improve our Sites and your experience. Information obtained from cookies and linked to personally identifying information is treated as Personal Information. If you wish to block, erase, or be warned of cookies, please refer to your browser manufacturer to learn about these functions. When you view a video on our Sites, a third party may also set a "flash cookie" on your computer. Removing and rejecting browser cookies does not necessarily affect third party flash cookies used in connection with our Sites. To delete or disable flash cookies, please visit http://www.adobe.com/products/flashplayer/security for more information. However, if you choose to remove or reject browser or flash cookies, this could affect certain features on our Sites. Web beacons are small, invisible graphic images that may be used on the Sites or in emails relating to the Sites to collect certain information about usage and campaign effectiveness and monitor user activity on the Sites. 3. Collection By Third Parties Third Parties may collect certain information from you when you use the Services. a. Electric Supply Service Whenever you sign-up for and use the Utility Services, your utility company will collect certain information from you including property address and utility company account number. Collection of such information by your utility company is not governed by this Policy. The terms of your utility company s privacy policies will apply. b. Sites 2
Third party vendors may use cookies or other technologies to serve ads on other websites based on your visits to the Site and other sites on the Internet. These third parties may automatically collect information about your visits to this and other websites, your IP address, your ISP, the browser you use to visit our Site. They do this by using cookies, clear gifs or other technologies. Information collected may be used, among other things, to deliver advertising on other websites targeted to your interests and to better understand the usage and visitation of our Sites and the other sites tracked by these third parties. This Policy does not apply to, and we are not responsible for, cookies or clear gifs used by the third parties, and we encourage you to check the privacy policies of advertisers and/or ad services to learn about their use of cookies and other technology. If you would like to opt out of these cookies or obtain more information related to third party advertising networks, click here: http://www.networkadvertising.org. In some cases, third party vendors may collect Personal Information from you, such as your name and email address, on other web sites and provide this information to us, or Ethical Electric may collect Personal Information that you enter directly within an advertising unit. This Policy does apply to such Personal Information collected online in this manner, and we will treat such information in the same manner as information collected on our Sites. c. Tracking We use Google tools including [Google Analytics and Google Advertising] to collect and track user statistics and trends related to our Sites and Services. As part of our use of Google Analytics and Advertising we will install cookies as set forth above. To opt out of having your activities tracked through Google Analytics and Advertising please visit: https://tools.google.com/dlpage/gaoptout/. C. How Do We Use the Personal Information We Collect? We use Personal Information collected for the purposes described in this Policy. We may use Personal Information we collect: to provide the services, products, or information you request, and to process and complete such requests and any related transactions; to provide the Utility Services; to send you confirmations, updates, alerts, and support and administrative messages and otherwise facilitate your use of, and our administration and operation of, the Electric Supply Service; to notify you about important changes to the Electric Supply Service or Sites; to perform analytics on our customer base to better understand how we can improve our Electric Supply Service; 3
to send you newsletters and otherwise provide you with information or services you request or that we think will be of interest to you, such as sending you information to keep you informed about various issues, events, resources, promotions, contests, discounts, products and services; to contact you if other information is necessary under federal or state laws; to request feedback and to otherwise contact you about your use of the Services; to respond to your emails, submissions, questions, comments, and requests and to provide customer service; to monitor and analyze site usage and trends, and to personalize and improve the Site and our users' experiences on the Site, such as providing content, or features that match your profiles or interests, and to increase the Site's functionality and user friendliness; to serve ads, on this or other websites or media, based on the information you provide and the actions you take; to notify and contact contest and sweepstakes entrants; and for any other express purpose for which the information was collected. D. What Personal Information Do We Share With Third Parties? It is our policy not to share the Personal Information we collect from you through our Services with third parties, except as described in this Policy or as otherwise disclosed to you. We may share Personal Information as follows with your local electric utility to fulfill enrollment of the Electric Supply Service; with vendors, consultants, partner organizations and other service providers or volunteers who are engaged by or working with us and who need access to such information to carry out their work for or with us; to report required information to any state or federal licensing authority for the purposes of compliance with our requirements under the law; when you give us your consent to do so, including if we notify you through the Services, that the information you provide will be shared in a particular manner and you provide such information; when we believe in good faith that we are lawfully authorized or required to do so or that doing so is reasonably necessary or appropriate to comply with the law or legal processes or respond to lawful requests, claims or legal authorities, including responding to lawful subpoenas, warrants, or court orders; when we believe in good faith that doing so is reasonably necessary or appropriate to respond to claims or to protect the rights, property, or safety of Ethical Electric, our users, our 4
employees, our volunteers, copyright owners, third parties or the public, including without limitation to protect such parties from fraudulent, abusive, inappropriate, or unlawful activity or use of our Sites or Utility Services; to enforce or apply this Policy, our Terms of Service, or our other policies or agreements; and in connection with, or during negotiations of, any reorganization, formation of a new company, asset sale or transfer, financing or lending transaction or in any other situation where Personal Information may be disclosed or transferred as one of the assets of Ethical Electric. If you do not want to have your Personal Information shared with any of these third parties, please contact us using the contact details at the end of this Policy. We are not responsible for the actions of any service providers or other third parties, nor are we responsible for any additional information you provide directly to any third parties, and we encourage you to become familiar with their privacy practices before disclosing information directly to any such parties. Nothing herein restricts the sharing of aggregated or anonymized information, which may be shared with third parties without your consent. E. What Steps Do We Take To Protect Your Information? We take reasonable measures to protect your Personal Information in an effort to prevent loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware, however, that despite our efforts, no security measures are perfect or impenetrable and no method of data transmission that can be guaranteed against any interception or other type of misuse. To protect the confidentiality of Personal Information, you must keep your password and account information confidential and not disclose it to any other person. You are responsible for all uses of Services by any person using your password. Please advise us immediately if you believe your password has been misused. F. Terms Specific to the Use of our Sites 1. Interactive Features You understand that when you use the Sites, information you post in your profile, blogs, forums and other interactive areas of the Sites, as well as any information you share with individuals through the Sites or share through social network sites, will be available to other users and, in some cases, may be publicly available. In addition, when you sign up and create an account, certain information regarding actions you take through the Sites, such as joining a group or actions tracked under the "Making a Difference" section of your profile, may be available to other users and, in some cases, may be publicly available. We recommend you be cautious about giving out Personal Information to others or sharing Personal Information in public or private online forums. We are not responsible for the actions of any third parties with whom you share Personal Information. In some cases, there may be privacy setting available regarding the information available to others, and we suggest you take time to familiarize yourself with these options and utilize these settings. 2. Social Plugins 5
The Sites may use social plugins ("Plugins"), which lets friends share actions they take across web sites (e.g. the Facebook "Like" button). Plugins are generally identifiable by the logo for the applicable social network or other notice indicating the use of a Plugin. When you visit a page of our website that contains a Plugin, your browser establishes a direct connection to the servers of the social network providing the Plugin, which enables that social network to receive certain information, such as information about your having accessed the respective page of our Site. If you are logged into the applicable social network, your visit can be assigned to the account of such social network. If you interact with the Plugins, for example by clicking "Like," or entering a comment, the corresponding information is transmitted from your browser directly to the social network providing the Plugin and is stored by it. Even if you are not logged into that social network, there is possibility that the Plugins transmit certain information, such as your IPaddress, to the applicable social networks. For information on the purpose and scope of data collection and processing by such social networks, as well as your rights in this respect and settings options for protecting your privacy please visit the privacy policy page for the social network providing the Plugin. If you do not want the social networks providing the Plugins to connect the data concerning your visit to our website with your member data already stored by such social networks, you must log off all such social networks before entering our website. Simply closing the social network page does not suffice. 3. Links to Other Websites Our Sites may contain links to other websites. Any Personal Information you provide on the linked pages is provided directly to that third party and is subject to that third party's privacy policy. This Policy does not apply to such linked sites, and we are not responsible for the content or privacy and security practices and policies of these websites or any other sites that are linked to from our Sites. We encourage you to learn about their privacy and security practices and policies before providing them with Personal Information. 4. Children Our Sites are not directed to children under the age of 13, if you are not 13 years or older, do not use our Sites. We do not knowingly collect Personal Information from children under the age of 13. If we learn that Personal Information of persons less than 13 years-of-age has been collected through our Site, we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child or a minor under the age of 13 has posted, submitted or otherwise communicated Personal Information to our Sites without your consent, then you may alert us at digital@ethicalelectric.com so that we may take appropriate action to remove the minor's Personal Information from our systems. In accordance with California law, minors under the age of 18 residing in California may remove or request and obtain removal of content and information that they post on the website or app. In order to remove or to request and obtain removal of such content and information, please email us at digital@ethicalelectric.com or call 1-800-460-4900. Users should be aware that removal of the content and information posted by a minor does not ensure complete or comprehensive removal of the content or information posted on our Sites. 6
Under certain circumstances, Ethical Electric may not have to comply with the above removal requirements. Ethical Electric also reserves the right, to the extent permitted by law, to anonymize the posted content or information or to make such content or information invisible to other users and the public instead of removing or deleting the content or information. 5. Do Not Track Policy Ethical Electric does not respond to web browser do not track signals. As such, your navigation of our Sites may be tracked as part of the gathering of quantitative user information described above. If you arrive at our Sites by way of a link from a third party site that does respond to do not track requests, the recognition of any do not track request you have initiated will end as soon as you reach our Site. G. Online Petitions If you sign an online petition that we provide, you understand that such petition is public information and that we may make the petition, and your name, city, state, and any comments provided in connection therewith publicly available. In addition, we may provide such petitions or compilations thereof, including your comments, name, city, and state to national, state or local leaders, or to the press. H. Your California Rights FOR RESIDENTS OF CALIFORNIA ONLY. Section 1798.83 of the California Civil Code requires select businesses to disclose policies relating to the sharing of certain categories of your personal information with third parties. If you reside in California and have provided your personal information to Ethical Electric, you may request information about our disclosures of certain categories of personal information to third parties for direct marketing purposes. Such requests must be submitted to us at one of the following addresses: digital@ethicalelectric.com or Ethical Electric Attn: California Privacy Rights 1055 Thomas Jefferson St. NW Suite 650 Washington, DC 20007 Within thirty (30) days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of those third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the address specified in this Section. I. What Choices Do You Have Regarding the Use of Your Information? You may "opt out" of receiving text messages, email updates and newsletters from us by following the instructions in those text messages and emails. Please note that we may still send 7
you other types of emails, such as emails about your use of our Services, or use information as otherwise described in this Policy, even if you opt out of receiving email updates and newsletters. You can view or modify information stored with your user account by logging in to your account and accessing the Manage My Account page. Changes to information in your account does not affect information previously provided to others as set forth in this Policy. J. Questions? If you have any questions about this Policy, please contact us at info@ethicalelectric.com. 8