CALIFORNIA PRIVACY NOTICE

Last Updated: November 18, 2024

This California Privacy Notice (the “Privacy Notice” or “Notice”) provides limited information to California residents only about how LGCY Power, LLC and its affiliates (“LGCY Group,” “we,” “us,” “our”) collects, uses, and discloses Personal Information. For more details about our privacy practices and any privacy rights you may have, please see our Privacy Policy. Neither this Notice nor the Privacy Policy apply to Personal Information we collect from or about job applicants, employees, or independent contractors, which are governed by the LGCY Employee and Contractor Privacy Notice.

Information We Collect From California Residents

We collect information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Information”), including:

• Identifiers such as name, signature, social security number, driver’s license number, mailing address, garaging address, email addresses, phone numbers, fax numbers, and LGCY Group account credentials;
• Characteristics of protected classifications under California or federal law such as age and gender;
• Other demographic information such as any co-owners or co-tenants of your home, and what languages you speak;
• Commercial information such as payment card or bank account information, your utility company and services your utility company provides, past and present energy generation and usage (including use generated by appliances and devices), pool and utility settings, dwelling age, size and type, whether you rent or own your home, details about appliances and other energy-related equipment used in the home or building, mapping information, details about the home or building’s structure for system design, data regarding solar irradiance, product interest and purchase history, financial account status and balance, and information about solar-related equipment in your home, including make, model, serial number, and location in your home, the energy it generates (including power, voltage, current, frequency and flow rates), its settings, schedules, alerts, system installation and roof diagrams;
• Internet or other electronic network activity information such as browsing/search history, IP address, and data collected by cookies and similar technologies;
• Geolocation data such as geographic location indicators from mobile, web, and product that are approximate and/or which are not used to locate a particular individual;
• Audio, electronic, visual, thermal, olfactory, or similar information such as call recordings, chat transcripts, testimonials, photos and satellite imagery of your home or building, and pictures or videos you upload to or send through the Website or by using our Services;
• Biometric Information such as a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry used to identify an individual. Our biometric disclosure is found here;
• Professional or employment-related information such as employer, job title, and income;
• Education information such as education level;
• Inferences drawn from other Personal Information or data that relate to your preferences, interests, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes, such as credit reports or credit scores; and
• Personal information as described in Cal. Civ. Code § 1798.80(e) to the extent collected under another category of Personal Information above.

Some of the Personal Information listed above may be considered Sensitive Personal Information under California law. This includes social security number, driver’s license and other identification card information, biometric information, and your LGCY Group account credentials. Each type of Sensitive Personal Information may overlap with a category of Personal Information listed above.

The type of Personal Information we collect about you may vary based on how you use the Site and/or Services and your relationship with us.

How We Use Information of California Residents

We use Personal Information for business purposes, such as:

• Account creation, fulfillment, servicing, and customer support: to process applications, create customer accounts, allow customers to create online accounts and profiles, provide goods or services, keep customers informed about the status of their services, respond to questions and addressing customers concerns, deliver updates, upgrades and product improvement information.
• Marketing and market research: to send communications and offers for our or third parties’ products and services, including offers based on consumers’ interests, personal and business characteristics and location; perform analytics for market and consumer research, trend analysis, financial analysis, and anonymization of personal information.
• Collection and credit reporting: to collect on outstanding balances, repossess collateral and update credit reporting agencies.
• Surveys, promotional events, contests: to administer surveys, polls, sweepstakes, contests, loyalty programs and other promotional events and contests.
• Other company communications: to provide consumers with information that may be of interest such as company newsletters, announcements, reminders, and technical service bulletins.
• Website use and analytics: to provide you with access to and use of our Website and Services; analyze consumers’ use of our websites, including the use of third-party web analytics services, which may utilize automated technologies to collect data (such as email and IP addresses).
• Eligibility and Pricing: to determine if consumers are eligible for certain products, services or offers and the pricing related to such offers.
• Product research: to conduct research and analysis for maintaining, protecting, and developing services, increase and maintain the safety of our products and services, and prevent misuse.
• Business operations: to evaluate, develop, and improve business operations, products and services offered; business administration and other normal business activities.
• Compliance: to comply with applicable legal requirements, industry standards, contractual obligations, our policies, and take actions that we deem necessary to preserve and enforce our rights and the rights of others.
• Information security and fraud prevention: to operate information security and anti-fraud programs.

We use Sensitive Personal Information as follows:

• Government Identifiers (social security numbers, driver’s licenses, and other government identification cards) – to provide the Services, service accounts, collect on accounts, and as otherwise required by law.
• LGCY Group account credentials – to permit access to customers’ online accounts and operate information security and anti-fraud programs.
• Biometric information – to confirm your identity as part of our anti-fraud programs.

We may also use Personal Information and/or Sensitive Personal Information as described to you at the point of collection or as otherwise required or permitted by California law. We only use Sensitive Personal Information related to California residents for purposes permitted by California Consumer Privacy Act regulations (11 CCR 7000 et seq.).

Third-Party Sales or Sharing

We may sell or share (for targeted or cross-context behavioral advertising purposes) your Personal Information with other companies who do not provide services to us (“Third Parties”).
In the past twelve months, we sold and/or shared Personal Information (except Sensitive Personal Information) as follows:

• Industry associations and advocacy groups: we sold identifiers, commercial information, and other demographic information to allows these associations and groups to provide consumers with information that may be of interest.
• Advertising, social media, and analytics companies: we sold and/or shared Identifiers and Internet or other electronic network activity information for the purposes described above. These companies may use your Personal Information for additional purposes outlined in their privacy policies.

We do not knowingly sell or share the Personal Information of consumers under 16 years of age.

How Long We Retain Your Personal Information

We may retain each category of Personal Information for as long as needed or permitted based on your relationship with us, our legal and regulatory obligations, and our need to retain information for normal business purposes, including marketing.