This Privacy Policy was last updated November 16, 2022. 

Solstice Power Technologies LLC. (“SPT) and Energy Allies, Inc. (“SI”) (collectively, “Solstice”, “we”, “our”, or us”) takes your privacy seriously and we encourage you to read this Privacy Policy carefully to understand how we collect and handle information that you provide to us. This Privacy Policy applies to the Solstice.us website (the “Site”), including but not limited to our proprietary platform and related services, any mobile applications that we may make available, and any of our products and services that link to this Privacy Policy (collectively the “Services”). If you do not agree to the terms of this Privacy Policy or our Terms & Conditions, please do not use our Site.

1. PERSONAL INFORMATION WE COLLECT AND HOW WE COLLECT IT. 

When we use the term “personal information” in this Privacy Policy, we are referring to any information or data that can be used to identify you.  We collect personal information in several ways.  Below we explain the types of information that we collect in each context.

Information You Provide to Us:

• Contact Information. We may collect your name, company, job title, email address, residential address, and phone number.
• Utility information. We collect certain utility information such as your utility account number, energy usage data, and, in certain cases, data related to your payment history.
• Payment Information. When purchasing our Services, you will need to provide certain payment information. This information is provided directly to our payment processing partners and is not stored at Solstice.  At no time does Solstice have access to your full payment card information. Payment information may include, but is not limited to: bank account numbers, account type, debit and credit card information, cardholder information including name, address, transaction card numbers, and personally identifying numbers.
• Consumer Credit Information. We may use consumer reports to determine your eligibility to obtain Services by evaluating your credit history and credit information. To do this, we collect your personal information, which may include information such as your date of birth, employment information, address, and Social Security number.  We use your credit information to perform a risk analysis or determine your eligibility for certain Services, and to provide our Services. We obtain this information through a soft credit inquiry only. Prior to performing a credit check, we will provide additional disclosures to you and we will obtain your consent.  Please note that we do not store your Social Security number.
• Prospective Employee Information. We accept employment applications on our Site. These applications contain personal information that we use to evaluate your candidacy for employment opportunities with us.  We retain this information in accordance with applicable law and internal retention policies.
• Phone Call Communication. We may record phone conversations for quality and training purposes. We will provide notice to you whenever we record any phone call.  

We or our third party community solar and other energy development partners (“Developers”) may collect information that you provide to us, including account information, contact information, and other personal information as defined under U.S. privacy law or this privacy policy. Account information includes the information you provide if you register with us, including email address and password.  We will also request other information as part of your account, including your name, company, demographic information and job title.  If you sign up for Services, we may share your personal information with Developers or owners of community solar projects.  Once shared, this privacy policy will also, and independently, apply to that personal information.

We may also use our third-party service providers, subject to your authorization, to collect information from your utility bill, as described above, so that we may provide you information and Services. Please note that this only occurs if you sign up for a project. These third-parties will exclusively share your utility information with us and no other third parties.  Similarly, they will only use your information to provide services to us.  To learn more about how such third parties handle your personal information, please review the applicable third party’s privacy policy.

We also collect personal information when you register with the Site or download content from the Site. We may use links throughout the Site to provide you with the opportunity to contact us via email or phone to ask questions or to provide comments or suggestions

Information We Collect Automatically:

As with most websites, when you use our Site or Services we automatically receive and collect information about you and your device.  This information includes the following:

• Information about your device, such as the operating system, hardware, system version, the Internet Protocol (IP) address, device ID, and device language. 
• The specific actions that you take when you use our Site or Services, including but not limited to the pages and screens that you view or visit, search terms that you enter, and how you interact with our Site or Services
• The time, frequency, connection type, and duration of your use of our Site or Services.
• Information regarding your interaction with email messages, for example, whether you opened, clicked on, or forwarded the email message.
• Identifiers associated with cookies or other technologies that may uniquely identify your device or browser (as further described below).
• Geolocation information from your device.
• Pages you visited before or after navigating to our Site.

Cookies and Analytics

As most websites and mobile applications do, we use analytics partners to collect certain information about how our Site and Services are used. We and our analytics partners use cookies, web beacons, and other technologies to receive and store certain types of information whenever you interact with our services through your computer or mobile device. A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. Cookies may store unique identifiers, user preferences and other information. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features or services may not function properly without cookies. We use cookies to analyze and improve our Site and Services, to store user preferences, track user trends, and provide relevant advertising to you. 

By using our Site and Services, you consent to the processing of your information by our analytics partners in the manner and for the purposes set out above. Currently, our analytics partners include, without limitation, Google Analytics, Mixpanel, and Segment. In order to ensure that you understand how our analytics partners handle your information and how they interact with our Site and Services, you should visit their privacy policies for more information, as we have no ability to control or monitor our analytics partners’ data collection or data use practices with respect to such information. 

At the present time our Site and Services do not respond to “Do Not Track” signals or similar mechanisms. 

Information We Receive from Third Parties:

We may receive information about you (including personal information) from third parties, such as, for example, via other websites. For example, when you interact with us through various social media, for example, by visiting our Facebook, LinkedIn, YouTube, Twitter, or Instagram page, we may receive information including your email address, location, and other biographical information. The information we receive from your social network depends on your privacy settings. You should always review, and, if you prefer, adjust your privacy settings on third-party websites and services before linking or connecting them to the Site. We may combine the information we receive from third parties with information that we collect through other means. In those cases, this Privacy Policy will apply to all personal information we have, unless we have stated otherwise.

We also receive personal information from the following Developers, as well as sales, marketing and other promotional partners.

2. HOW WE USE INFORMATION.

General. In general, we collect personal information so that we can provide our Services, operate our business, and provide information that you request from us.  This also includes evaluating your eligibility for our Services and projects, conducting research for the purposes of making out Site and Services more efficient and effective, responding to your questions or requests, providing the Site and the Services that you request, communicating with you about our Site or Services, administer promotions and discount programs, and administering the Site and our Services, and managing, protecting, and improving them. We may also use your personal information to send you emails or mailers about our company, the Site, our Services, new products, special deals, or other similar matters in accordance with your preferences (see “How You Can Access or Correct Your Information or Opt Out” in Section 8 below). 

Consumer Credit Information.  As discussed above, we use consumer credit information to determine your eligibility for certain Services, to perform a risk analysis, and to provide our Services.  If we take any adverse action against you on the basis of your credit history or credit information, such as rejecting your application to use our Services or charging you a different price based on such information, we will notify you in writing of such adverse action. Such communication will also notify you of your rights and contain additional information as required by law. 

We do not share this information with third parties except as necessary to provide the Services, such as verifying your eligibility to use the Services with our Developers.  However, we do not share your numerical credit score with Developers – only whether your score meets or exceeds the applicable eligibility requirements. 

Necessary Uses.  We also use your information for the following necessary purposes:

• As necessary to comply with any applicable law, regulation, subpoena, legal process, or governmental request.
• Enforce contracts and applicable Terms of Service, including investigation of potential violations thereof.
• Detect, prevent, or otherwise address fraud, security or technical issues.
• Protect against harm to the rights, property or safety of Solstice, our Developers, customers, other third parties, or the public as required or permitted by law.

3. HOW WE SHARE INFORMATION.

Affiliates and Subsidiaries.  

We may disclose your personal information and other information we collect to affiliates or subsidiaries that require access to your personal information for business purposes. In particular, we may share your personal data with our affiliates to improve our EnergyScore technology. 

Legal Proceedings. 

We may share personal information with third party companies, organizations, governmental authorities, or individuals outside of Solstice if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

• Meet any applicable law, regulation, subpoena, legal process or governmental request;
• Enforce a contract, including but not limited to any applicable Terms of Service, including investigation of potential violations thereof;
• Detect, prevent, or otherwise address fraud, security or technical issues; or
• Protect against harm to the rights, property or safety of Solstice, our users, customers or the public as required or permitted by law.

Service Providers.

We also may provide your personal information to vendors who provide services on our behalf, such as our third-party website developer, analytics provider, email management vendor, or customer records management vendor. If you request services via a mobile device, your request will be transmitted via your mobile carrier’s network and your carrier may have access to it. Consult your carrier’s privacy policy for additional information.

Sale or Merger.
We may share personal information about you as part of a merger or acquisition. If we are involved in a merger, asset sale, financing, liquidation or bankruptcy, or acquisition of all or some portion of our business to another company, we may share your information with that company before and after the transaction closes. In such a case, unless permitted or otherwise directed by applicable law, your information would remain subject to the terms of the applicable privacy policy in effect at the time of such transfer.

Payment Processors 

If you purchase our Services, your credit card or debit card information (such as card type and expiration date) and other financial data that we need to process your payment may be collected and stored by the payment processors with which we work, as well as third party processors that assist us with recurring payment options. We may also collect some limited information, such as your postal code, mobile number, and details of your transaction history. In addition, the payment processors generally provide us with some limited information related to you, such as a unique token that enables you to make additional purchases using the information they’ve stored, including recurring payments, and your card’s type, expiration date, and certain digits of your card number.

As Directed By You and With Your Consent

Except as otherwise provided in this Privacy Policy, we share personal information with companies, organizations or individuals outside of Solstice only at your direction or when we have your consent to do so.

Aggregate Information

We may de-identify or aggregate personal information so that you are not identified as an individual, and use and provide that information to third parties without restriction. We may also provide aggregate usage information to third parties (or allow third parties to collect that information from you), who may use such information to understand how often and in what ways people use our services. However, we never disclose aggregate usage or de-identified information to a third party (or allow a third party to collect such information) in a manner that would identify you as an individual person. 

4. SECURITY.

We implement and maintain reasonable safeguards to protect the security, confidentiality, and integrity of the personal information, including safeguards that protect the personal information when the person disposes of the personal information. We use precautions, including technical, administrative, and physical procedures, to protect personal information from loss, misuse, or alteration. However, guaranteed security does not exist on the internet or offline and we cannot guarantee that information you provide to us, and communications between you and our servers, will be free from unauthorized access by third parties.

5. CHILDREN.

The Site and Services are not intended for use by children under the age of 18, and we do not knowingly collect personal information from anyone under age 18. If we learn that we have collected the personal information of anyone under age 18, we will delete the information as soon as possible. 

6. CALIFORNIA PRIVACY RIGHTS. 

Pursuant to Section 1798.83 of the California Civil Code, California residents have the right to request from a business with whom the California resident has an established business relationship what types of personal information, if any, the business shares with third parties for direct marketing purposes by such third parties and the identities of the third parties with whom the business has shared such information in the immediately preceding calendar year. We do not currently provide any personal information to third parties for their own direct marketing purposes. If you have any questions, comments, or requests related to this Section, please contact us via email at info@solstice.us. If we change this policy, we will update this provision and provide instructions on how you may make a request for details. 

7. NEVADA RESIDENTS

Nevada customers can opt out of the sale of their personal information.   We do not sell personal information today, and we do not have plans to sell personal information in the future.   However, Nevada customers have the legal right to opt out of the sale of their personal information, even if their information is not currently being sold.  You may opt out by emailing a request to info@solstice.us.  In your request, please specify that you wish to “Opt-out of Sale of Personal Information in Nevada.”   Please allow 60 days for a response.

8. YOUR PRIVACY CHOICES. 

Account Information.  If you have created an account with us in the Services, you may access and make changes to certain information in your account by logging into your account.  If you need additional assistance with updating your account information, please contact us info@solstice.us.  

Opt-Out of Marketing Communication.  If you receive e-mails from us and want to opt-out of receiving further marketing e-mails, simply click the “unsubscribe” link made available at the bottom of our correspondence. Note that even if you opt-out from receiving promotional and marketing material, we will still contact you about your existing or past business relationships with us.

SMS Text Communication. If you opt-in, we may send you SMS text messages about our Services and to alert you to relevant advertisements and other opportunities, which may be automated.  To stop receiving SMS text marketing communications from us, you may text “STOP”, “END”, “CANCEL”, “UNSUBSCRIBE”, or “QUIT” to a text message from us. After texting STOP, END, CANCEL, UNSUBSCRIBE or QUIT to our shortcode you will receive one additional message confirming that your request has been processed. If you unsubscribe from one of our text message programs, you may continue to receive text messages from us through any other programs you have joined until you separately unsubscribe from those programs.

9. LINKS TO THIRD-PARTY WEBSITES; SOCIAL MEDIA PLUG-INS. 

The Site may contain links to third-party websites that are not controlled by us (such as “Share” or “Like Page” on Facebook or “Tweet” on Twitter). These links are made available to you as a convenience, and you agree to use these links at your own risk. Please be aware that we are not responsible for the privacy practices or content of such third-party websites. If you navigate to a third-party website from the Site, we strongly encourage you to review and become familiar with that third-party website’s own privacy policy and statements. Use of third-party social networking websites, such as Twitter, Facebook, and LinkedIn, are governed by the privacy policies and practices of those websites.

10. NOTICE TO RESIDENTS OF COUNTRIES OUTSIDE THE UNITED STATES. 

We are based in the United States and our Site and Services are hosted there. Your personal information may be accessed by us or transferred to us in the United States or to our affiliates, business partners, or service providers elsewhere in the world. If you are located outside of the United States, be advised that any information you provide to us will be transferred to and stored in the United States and that, by submitting information to us, you explicitly authorize its transfer and storage within the United States.

11. CHANGES TO PRIVACY POLICY. 

We may make changes to this Privacy Policy from time to time. When we do, we will post the updated version on this page. We encourage you to read this page each time that you use our Site or Services so that you will be aware of any changes, and your continued use of our Site or Services shall constitute your acceptance of any such changes. Changes to this Privacy Policy take effect from the date of publication, unless stated otherwise. 

12. HOW TO CONTACT US. 

Should you have other questions or concerns about this Privacy Policy, please contact us by email at info@solstice.us.