ALTUS POWER, INC[ZG1] . (“Altus”, “we”, “our”) respects your privacy. This Privacy Policy describes the types of data we collect about our customers and users of our website at www.altuspower.com (the “Site”) (together with the services we provide, our mobile application and any other services where this Privacy Policy is posted, collectively, the “Services”), how we use the data, and how we disclose it.  

By using the Services, including by visiting our Site, you acknowledge the applicability of this Privacy Policy and represent that you have read, acknowledge, and consent to the collection, use and disclosure of your information in accordance with this Privacy Policy. If you do not agree with this Privacy Policy, you should not use the Services. This Privacy Policy does not apply to websites that we do not operate.

This Privacy Policy consists of the following sections:

1. Data We Collect
2. How We Use The Data We Collect
3. How We Disclose Data
4. Data Transfers
5. How We Protect Data
6. Retention
7. Analytics and Advertising
8. Your Rights and Choices
9. California Consumer Privacy Notice
10. Supplemental Notice for Residents of Other States
11. Children’s Privacy
12. Third Party Sites
13. Updates to Our Privacy Policy
14. How to Contact Us
15. Notice for California Employees and Job Applicants

1. Data We Collect

Data you provide to us. We collect data you provide to us, including when you create an account, communicate with us (e.g., email us or fill out a form on our Site), or otherwise interact with us online or offline. Such information may include:

• Contact information, including your name, address, phone number, and email address;
• Account details, including password and your utility API authentication information;
• Financial details, including billing information and payment information;
• Information about whether you are participating in a program for financing your use of our Services,     including documentation such as your paystubs, W2, tax documents, or proof of participation in a government program;
• Geolocation information;
• Company name, business contact information, fuel usage, and building information (for business customers);    
• Other information related to you, including your date of birth and utility provider; and
• Any other data that you provide to us.

Some information may be required to subscribe to our Services.

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Data collected automatically. We may collect certain data automatically, some of which is collected using cookies and other similar technologies, and which may include:

• Browser and device data, such as IP address, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, time zone, plug-ins and add-ons, and system settings. Much of this information is stored in log files and is used to maintain and improve the performance of the Services;
• Usage data, such as time spent on our website, pages visited, links clicked, language preferences, and the pages that led or referred you to our website.

Cookies and Similar Technologies

Like many online services, we use cookies and similar technologies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We and some third parties may use both session Cookies (which expire once you close your web browser) and persistent Cookies(which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Services and to market the Services or other products. We may use cookies to collect information about your online activities on websites and connected devices over time and across third-party websites, devices, apps and other online features and services. To learn more about the cookies that may be served through our website and how you can control our use of cookies and third-party analytics, please see Your Rights and Choices. [ZG2] 

2. How We Use the Data We Collect

We may use the data that we collect for any of the following business purposes in this section.

• To perform our contracts with customers, including in order to provide you with the Services, set up and maintain customer accounts, for accounting and invoicing purposes, to manage contracts, orders, and subscriptions, to provide troubleshooting and customer support services, for user authentication and security purposes, and to create a usage report and log for each user.
• To manage  our customer relationships and communicate with our customers, in order to administer our business and to update our customers about new features and services that we may offer;
• To address complaints and handle disputes ;
• To enforce applicable Altus policies and procedures relating to our Services, including our Terms of     Use;
• To protect you and our Services, including through fraud detection and prevention;
• To perform analytics, in order to identify potential improvements to our Services and to measure     engagement with our advertising campaigns;
• To market and advertise and to administer sweepstakes and contests (including to notify winners);
• To process data when we are required to do so by law, for example in order to maintain accounting records; to comply with applicable laws, regulations, and legal process; and to protect the safety, rights, and property of you, ourselves and others; and

To process data for other purposes when you consent to such processing and/or as otherwise permitted by applicable laws.

We may aggregate and de-identify data. We may use appropriately aggregated and/or de-identified data for any purpose and disclose such data to any party for any purpose, in our discretion.

3. How We Disclose Data

We may disclose data to thefollowing types of entities and in the following circumstances.

• Affiliates: We may disclose your data to other entities in the Altus group of companies for the purposes described in this Privacy Policy.
• Vendors: We may disclose data to vendors that provide us with services, including without limitation payment processors, customer support service providers, web hosting providers, and advertising and marketing providers.
• Data Partners: We may disclose data to certain data partners that require it under their terms in order for us to allow access to their data, such as the UTPPlan, the Consolidated Tape Association. We will not disclose your data to third parties for their own marketing purposes.
• Legal Compliance and Safety: We may disclose your data (i) if we are required or permitted to do so by law or legal process, for example due to a court order or a request from a law enforcement agency, (ii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, (iii) in connection with an investigation of suspected or actual fraudulent or other illegal activity, and (iv) to exercise and defend our legal rights and obtain legal counsel.
• Corporate Transfers: We may disclose your data in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, liquidation or due diligence in connection with a similar transaction).
• With Your Consent: We may disclose your data consistent with your consent to do so.

4. Data Transfers

We may transfer the data that we collect about you to recipients in countries other than the country in which the data originally was collected, including the United States. Those countries may not have the same data protection laws as the country in which you initially provided the data or where you live, and data may be accessible to law enforcement and national security authorities under certain circumstances. By using the Services or providing us with any information, you consent to your information being stored in, processed in, and transferred to the United States and other applicable countries.

5. How We Protect Data

Altus maintains technical and organizational safeguards to ensure an appropriate level of security and confidentiality for your data, in accordance with our policies and applicable legislation.However, no method of transmission over the Internet, or method of electronic storage, is completely secure, so we cannot guarantee complete security of your data. You provide data at your own risk.

6. Retention of Data

The time period for which we retain data depends on the purpose for which we collect and use it. In all cases we keep data for as long as necessary to fulfill the purposes for which we collected it. We will then delete the data, unless we are legally required to retain it or if we need to retain it in order to comply with our legal obligations (for example, for tax and accounting purposes).

7. Analytics and Advertising

We use tracking and analytics services such as Google Analytics to track and analyze how visitors use our Services. Google's right to use and share information collected by Google Analytics about your visits to the Services is governed by the Google Analytics Terms ofService and the Google Privacy Policy. In addition, we work with agencies, ad networks, and other advertising companies to place ads for our products on other websites and services. For example, we place ads through Google, Facebook, LinkedIn and others that you may view on their platforms as well as on other websites and services.

As part of this process, we may incorporate tracking technologies (including cookies and pixel tags) on our Services in order to provide you with tailored advertisements across the Internet. These tracking technologies may collect information about your activity across time and services (including on our Services and other websites such as web pages you visit and your interaction with our advertising and other communications) and use this information to make predictions about your preferences, develop personalized content, compile reports and deliver ads that are more relevant to you on other websites ("Interest-based Advertising").This information may also be used to evaluate the effectiveness of our online advertising campaigns.

We also use audience matching services to reach people (or people similar to people) who have visited our Services or are identified in one or more of our-databases (" MatchedAds") by us uploading a customer list to a technology service or incorporating a pixel from a technology service into our ownServices, and the technology service matching common factors between our data and their data. For instance, we incorporate the Facebook pixel on our Services and may share your email address with Facebook as part of our use of FacebookCustom Audiences.

For further information on the types of tracking technologies we use on the Services and your rights and choices regarding analytics, Interest-based Advertising, and Matched Ads, please see the "Information Collected Automatically" "Your Rights and Choices" sections

8. Your Rights and Choices

Your Privacy Legal Rights. Depending on your residency (including California, Virginia, Colorado, Connecticut and Utah), and in accordance with applicable laws, you may have the right to request that we:

• Provide you the categories of personal information (as defined in the applicable laws)we collect and how we process it;
• Provide access to and/or a copy of certain information we hold about you;
• Provide you the opportunity to correct inaccurate information we have about you; and
• Delete certain information we have about you.

To exercise any of these rights, please submit a request through our online form available through our online request portal, call our toll-free number at 1.888.88.ALTUS, or email us at hello@altuspower.com.

Depending on where you live, you may be able to designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent's permission to do so and verify your identity directly.

If we deny your request in whole or in part, you may have the right to appeal the decision depending on where you live by contacting hello@altuspower.com.

Your Privacy Choices.

Opt Out of Sale or Share or Processing of Personal Information for TargetedAdvertising.

Residents of certain states such as California, Colorado, Connecticut Utah, and Virginia may opt out of the "sale" of their personal information. Such residents may also opt out of the sharing or processing of their personal information for targeted advertising. Applicable law broadly defines"sale" or "share" in a way that may include allowing third parties to receive certain information such as cookies, IP address, device identifiers, browsing behavior, contact information and/or other activity to enable targeted advertising to you. We may share or process such information to deliver targeted advertising to you about our Services.

If you or your authorized agent (where legally applicable) would like to opt out of the processing of your information for such purposes, you may submit a request by clicking on the Your Privacy Choices link in the footer of our website and following the instructions. For non-cookie based information, you may also use our online request portal or by email at hello@altuspower.com.

You may still receive advertising; it just may not be tailored to your interests.Please note, if you use different browsers, devices, or services you will need to make your choice on each browser or device where you want to opt out. You should also complete the form above so we may add your information to an appropriate suppression list.

Please note that if you have a legally recognized browser-based opt out preference signal turned on via your device browser (such as Global Privacy Control), we recognize such preference in accordance and to the extent required by applicable law.

Tracking Technology Choices.

Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete non-essential cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations. If you disable or remove tracking technologies some parts of the Site may not function correctly.

Your browser settings may allow you to automatically transmit a "Do Not Track" signal to online services you visit. Because there is no industry consensus as to what website operators should do with regard to these signals, we do not take action with respect to "DoNot Track" signals or other mechanisms, except as otherwise provided herein. For more information on "Do Not Track," visit http://www.allaboutdnt.com.

Analytics and Targeted Advertising Choices.

You can opt out of the processing of certain data collected by Google Analytics, by downloading and installing the browser plug-in available at https://tools.google.com/dlpage/gaoptout. For targeted advertising, in addition to the opt outs described in Your Rights and Choices above, some of the companies we work with to provide you with targeted ads are required by us to give you the choice to opt out of receiving targeted ads. Most of these companies are participants of the Digital Advertising Alliance (" DAA") and/or the Network Advertising Initiative (" NAI"). For more information about Interest-based Advertising and to understand your options, including how you can opt-out of receiving behavioral ads from participating companies, please visit the DAA website opt-out at http://www.aboutads.info/choices , or the NAI opt-out at https://www.networkadvertising.org/choices/ . Even if you opt-out of interest-based advertising by a participant, tracking technologies used on the Services may still collect data for other purposes including analytics. You may still see ads from us, but the ads from the participants with whom you opted out will not be targeted based on behavioral information about you and may therefore be less relevant to you and your interests.

Please note that your opt out only applies to the specific web browser you use so you must opt out of each web browser on each device you use. To successfully opt out, you must have cookies enabled in your web browser (see your browser's instructions for information on cookies and how to enable them). Once you opt out, if you delete your browser's saved cookies, you will need to opt out again.

To opt out of us using your data for Matched Ads, you may submit a request through our online form available through our online request portal. We will request that the applicable technology service not serve you Matched ads based on information we provide to it. Alternatively, you may directly contact the applicable technology service to opt out.

We are not responsible for the effectiveness of, orcompliance with, any opt out options or programs, or the accuracy of anycompany statements regarding their opt out options or programs.

Do Not Track Signals

Please note that we do not recognize or respond to “DoNot Track” signals (a privacy preference that can be set in some browsers), as the Internet industry is currentlystill working on Do Not Track standards, implementations, and solutions. Pleasenote that Do Not Track is different than the legally recognized browser-based opt-out signalsreferenced below.

MobileApp Notifications. Our mobile app may send you notifications. If you donot wish to receive notifications, you can turn them off via your devicesettings.

YourMarketing Choices. Weand our vendors, including our third-party advertising partners, may collectand use your data for marketing and advertising purposes. We may send you AltusPower-related direct marketing communications as permitted by law, including byemail and text messages. To opt out of marketing communications or to requestto be added to our Do Not Call List or Do Not Mail List, you may use one ofthese methods:

• Email Offers: If     you receive marketing emails from us, you may unsubscribe at any time by     following the instructions contained within the email, or by sending us an     email or writing to us at the addresses listed below. It may take up to 10     days to process your request. You should note that unsubscribing from our     emails will not automatically unsubscribe you from emails sent by any     third party, and you will need to separately unsubscribe from such third     party's communication, if desired. Also, unsubscribing from marketing     emails will not stop you from receiving non-marketing emails, such as     account-related emails, transaction-related emails, or emails about     updates to our policies.
• Direct Mail Offers: If     you do not wish to receive marketing by postal mail, send us an email or     write to us at the addresses listed below.
• Telemarketing: If     you do not want to receive marketing phone calls from us, you may: (i)     email us at info@altuspower.com with     "Do Not Call" in the subject line; (ii) ask to be placed on our     Do Not Call list when you receive a call from us; or (iii) mail us at the     address listed below. Once we place your name on our internal "Do Not     Call" list, we will no longer call you for marketing purposes (unless     you submit another inquiry or request another consultation/quote from us     after your initial do-not-call request). We will honor your request as     soon as reasonably practicable. 

9. California Consumer Privacy Notice 

This California ConsumerPrivacy Notice (“Notice”) supplements the Privacy Policy above and appliessolely to California residents. The California Consumer Privacy Act (asamended, “CCPA”) requires us to provide you with certain additional informationabout how we collect, use, and disclose your “personal information” (as definedin the CCPA) that we collect online and offline. This Notice does not apply toAltus’s personnel or job applicants. Inthis Notice, where we use a term in “quotes,” we are referring to the meaningof that term in the CCPA.

A.  Categories of Personal Information WeCollect, Use, Disclose, and Retain

Throughout thisPrivacy Policy, we discuss in detail the specific pieces of personalinformation we collect, the sources of that information, and how we discloseit. Under the CCPA, we also must provide you with the "categories" ofpersonal information and sensitive personal information we collect and disclosefor “business or commercial purposes”.

As described further in thePrivacy Policy above, the following table provides information about ourpractices in the 12 months leading up to the effective date of this PrivacyPolicy in relation to the categories of personal information that we generallycollect from California and Colorado residents, the purposes for which we usethe information, and the categories of other parties to whom we disclosepersonal information for a business purpose.

As used below,unless otherwise specified, “Perform our contract with you” includes thefollowing uses of personal information as listed above: to provide you with theServices, to set up and maintain customer accounts, foraccounting and invoicing purposes, to manage contracts, orders, andsubscriptions, to provide troubleshooting and customer support services, foruser authentication and security purposes, and to create a usage report and logfor each user.

Category of Personal Information Collected

Categories of Sources of  Personal Information

Purposes of Use

Categories of Other  Parties to Whom We Disclosed This Personal     Information

Identifiers  (such as name, email address, address, phone number, account name, IP  address, and device and cookie IDs)

You

Your  use of the Services and other interactions with us

Affiliates

Perform  our contract with you

Maintain  customer records

Manage  customer relationships and communicate with you, such as for customer service  and to send service notices

Address  complaints

Enforce  our policies

Security  and fraud prevention

Analyze  and improve the Services

Marketing  and advertising

Legal  and compliance purposes, including exercising our legal rights

Protect  the safety, rights, and property of ourselves and others

With  your consent

Affiliates

Vendors  

Advertising  and Analytics providers

Other  parties for legal and compliance purposes, or to protect us or others

Other  parties with your consent

Commercial  information (such as your purchase history and transaction information)

You

Your  use of the Services and other interactions with us

Affiliates

Perform  our contract with you

Maintain  customer records

Manage  customer relationships and communicate with you, such as for customer service  and to send service notices

Address  complaints

Enforce  our policies

Security  and fraud prevention

Analyze  and improve the Services

Marketing  and advertising

Legal  and compliance purposes, including exercising our legal rights

Protect  the safety, rights, and property of ourselves and others

With  your consent

Affiliates

Vendors  

Other  parties for legal and compliance purposes, or to protect us or others

Other  parties with your consent

Financial  and related information (such as payment card information and documentation  about your participation in programs to finance our Services, including, for  example, your W2 or tax documents)

You

Your  use of the Services and other interactions with us

Affiliates

Perform  our contract with you

Maintain  customer records

Manage  customer relationships and communicate with you, such as for customer service  and to send service notices

Address  complaints

Enforce  our policies

Security  and fraud prevention

Analyze  and improve the Services

Legal  and compliance purposes, including exercising our legal rights

Protect  the safety, rights, and property of ourselves and others

With  your consent

Affiliates

Vendors  

Other  parties for legal and compliance purposes, or to protect us or others

Other  parties with your consent

Professional  and employment-related information (such as your company name and your  business address, phone number, and email address)

You

Your  use of the Services and other interactions with us

Affiliates

Perform  our contract with you

Maintain  customer records

Manage  customer relationships and communicate with you, such as for customer service  and to send service notices

Address  complaints

Enforce  our policies

Security  and fraud prevention

Analyze  and improve the Services

Marketing  and advertising

Legal  and compliance purposes, including exercising our legal rights

Protect  the safety, rights, and property of ourselves and others

With  your consent

Affiliates

Vendors  

Other  parties for legal and compliance purposes, or to protect us or others

Other  parties with your consent

Geolocation  data

You

Your  use of the Services and other interactions with us

Affiliates

Perform  our contract with you

Maintain  customer records

Manage  customer relationships and communicate with you, such as for customer service  and to send service notices

Address  complaints

Enforce  our policies

Security  and fraud prevention

Analyze  and improve the Services

Marketing  and advertising

Legal  and compliance purposes, including exercising our legal rights

Protect  the safety, rights, and property of ourselves and others

With  your consent

Affiliates

Vendors  

Other  parties for legal and compliance purposes, or to protect us or others

Other  parties with your consent

Internet or  other electronic network activity information (such as cookie information,  device and operating system information, browsing  history, and information about your interaction with our Site)

You

Your  use of the Services and other interactions with us

Affiliates

Perform  our contract with you

Maintain  customer records

Manage  customer relationships and communicate with you, such as for customer service  and to send service notices

Address  complaints

Enforce  our policies

Security  and fraud prevention

Analyze  and improve the Services

Marketing  and advertising

Legal  and compliance purposes, including exercising our legal rights

Protect  the safety, rights, and property of ourselves and others

With  your consent

Affiliates

Vendors  

Advertising  and analytics providers

Other  parties for legal and compliance purposes, or to protect us or others

Other  parties with your consent

Other  information that identifies or can be reasonably associated with you (such as  your date of birth, any information you include in communications with us)

You

Your  use of the Services and other interactions with us

Affiliates

Perform  our contract with you

Maintain  customer records

Manage  customer relationships and communicate with you, such as for customer service  and to send service notices

Address  complaints

Enforce  our policies

Security  and fraud prevention

Analyze  and improve the Services

Marketing  and advertising

Legal  and compliance purposes, including exercising our legal rights

Protect  the safety, rights, and property of ourselves and others

With  your consent

Affiliates

Vendors  

Other  parties for legal and compliance purposes, or to protect us or others

Other  parties with your consent

We retain personalinformation as described in the “Retention of Data” section above.

We collect account logininformation (username and password), which under the CCPA is “sensitivepersonal information.” The CCPA provides you with the right to limit certainuses of sensitive personal information. However, we do not use this information forpurposes that you can limit.[ZG3] 

B.  California Consumer Privacy Rights 

Ifyou are a California resident, the CCPA may permit you to request that we:

• Provide you the categories of     personal information we have collected or disclosed about you; the     categories of sources of such information; the business or commercial     purpose for collecting, “selling,” or “sharing” your personal information;     the categories of third parties to whom we disclose or “sell,” or with     whom we “share,” personal information; and the categories of personal     information we “sell” or “share” (much of which is provided above).

·     Provideaccess to and/or a copy of certain personal information we have aboutyou. 

·     Deletecertain personal information we have about you. 

·     Correctinaccuratepersonal information that we have about you.

·     Optout of the “sale” and “sharing” of your personal information (see the sectionbelow titled “‘Sales’ and ‘Sharing’”).

You may havethe right to receive information about the financialincentives that we offer to you, if any. You also have the right to not bediscriminated against (as provided for in applicable law) for exercisingcertain of your rights.

Certaininformation may be exempt from such requests under applicable law. For example,we need certain types of information so that we can provide the Services toyou. If you ask us to delete it, you may no longer be able to access or use theServices. We reserve the right not torespond to requests where we have no legal obligation to do so.

Tosubmit a request for yourself or as an authorized agent on behalf of aconsumer, email us at legal@altuspower.com[ZG4] . We will take steps to verify your identitybefore complying with your request. If you have an account with us, we mayverify your identity by requiring you to sign in to your account. If you do nothave an account with us, we may require you to provide any of the followinginformation: email address; postal address; telephone number, or otherinformation. In addition, if you do not have an account and you ask us toprovide you with specific pieces of personal information, we may require you tosign a declaration under penalty of perjury that you are the consumer whosepersonal information is the subject of the request. To the extentpermitted by applicable law, we may charge a reasonable fee to comply with yourrequest.

C.“Sales”and “Sharing”[ZG5] 

The CCPA placescertain obligations on businesses that “sell” or “share” personal information forpurposes of “cross-context behavioral advertising”, as defined in the CCPA. Ourdisclosure of personal information to third parties for purposes of analyticsand certain types of advertising is considered a “sale” of personal informationor the “sharing” of personal information for purposes of “cross-contextbehavioral advertising.” We do not knowingly “sell” or “share” the personalinformation of children under 16.

In the 12 months leading up to the effective date ofthis Privacy Policy, we have “sold” or “shared” – under the CCPA’s definitionof these terms – the following categories of personal information: identifiers,Internet or other electronic network activity information,commercial information, [add any other categories that are collected by ad and analyticscookies[ZG6] ].

You have theright to opt out of “sales” and “sharing” of personal information. Pleasesubmit your request here: Your Privacy Choices[ZG7] .

Pleasenote that we also respond to and abide by opt-out preference signals sentthrough the Global Privacy Control. Any opt out preferences you have exercisedthrough these methods will only apply to the specific device/browser on whichyou made them. For more information on how to use the Global Privacy Control,see www.globalprivacycontrol.org[ZG8] 

D.  California “Shine the Light” Disclosure

UnderCalifornia’s “Shine the Light” law gives residents of California, underCalifornia Civil Code § 1798.83, you have the right to opt out of ourdisclosure of certain categories of “personal information” (as defined in theShine the Light law) to third parties for their marketing purposes. To makesuch a request, please contact us using the information in the “How to ContactUs” section of this Privacy Policy. Please note that we do not disclosepersonal information to third parties for their own marketing purposes.

10. Supplemental Notice for Residents of Colorado

Residents ofColorado may click here [ZG9] to view more information regarding eachcategory of personal information we process (including sensitive data (called“sensitive personal information” above)), the purposes for which we processeach category and the categories of entities to whom the personal informationis disclosed. Residents of Colorado may click here [ZG10] toview more information about the categories of personal information that are“sold” (as defined in Colorado law) or used for “targeted advertising” (asdefined in Colorado law, defined as “sharing” by the CCPA). Please note that wedo not engage in profiling that produces legal or similarly significanteffects.

11. Children’s Privacy

Wedo not knowingly solicit or collect personal information (as defined in applicablelaw) from children under the age permitted by applicable law without parentalconsent. If you are a parent or guardian age and believe that your childdisclosed information to us in a way that is prohibited by applicablechildren's privacy laws, please contact us usingthe information in the “How to Contact Us” section of this Privacy Policy.

12. Third Party Sites

The Servicesmay contain links to other sites, products, and services that are external andnot owned or controlled by us and to which this Privacy Policy does not apply.We are not responsible for the privacy practices employed by, or content providedby, such other sites, products, and services. We encourage you to be aware whenyou leave Services and to review the privacy policies of any third-partywebsites or services, as you will be subject to their policies, rules, andterms.

13. Updates to Our Privacy Policy

This Privacy Policy may beupdated periodically. We will post a notice on our Site to notify you of anysignificant changes to our Privacy Policy and indicate at the top of thePrivacy Policy when it was most recently updated. Updates to this PrivacyPolicy are effective immediately upon posting, and by continuing to use theServices after an update, you acknowledge and accept the updated PrivacyPolicy.

14. How to Contact Us

If you have questions abouthow Altus handles your data or would like to exercise your rights, please reachout by emailing or writing to us at:

Altus Power, Inc.

2200 Atlantic St Floor 6

Stamford, CT 06902

Attention: Altus Legal

Email: legal@altuspower.com

 [ZG1]Theemployee privacy policy at the end of this section refers to “Altus PowerAmerica Management, LLC”. What entity name is correct here?

 [ZG2]Altus:We do not see a Altus Cookie Policy. This links to: https://www.iexcloud.io/privacy/#cookieswhich is a different company.

 [ZG3]Thisstatement is true if you only use login information to log people into theiraccounts or for security reasons (or a few other purposes). Please confirm howyou use this information.

 [ZG4]Doyou interact with consumers solely online? If not, you’ll need a toll-freenumber in addition to this email address for people to submit requests.

 [ZG5]Yourprivacy policy currently says that you do not “sell” personal information, butbecause you use targeted advertising and analytics cookies, you do “sell” and“share” personal information as those terms are defined in the CCPA and otherstate privacy laws. We added the required disclosure here.

 [ZG6]Advertisingand analytics cookies almost always collect identifiers and internetactivity. They usually also collect commercial information such asproducts/services someone buys/uses (to serve ads like: if you bought/used x,you may be interested in y). So we added those categories here. However, cookiesare capable of collecting other categories of PI. Please check whether your adand analytics cookies collect any categories of PI that are not alreadystated here. You should be able to do that on the backend by looking at how thecookie is configured.

 [ZG7]Youwill need a sale/share opt out mechanism on your website. We recommend titlingthat page “Your Privacy Choices.” You should link to that page here. We candiscuss how to set up that page separately.

 [ZG8] [ZG8]Youare legally required to comply with GPC – you can either do this in house orget a third party consent management platform like OneTrust to do this for you.If you want to post the privacy policy before you can recognize GPC, we shoulddelete this section and only add it when you can recognize GPC. This is a highpriority item because it is an easy way for the California regulators to dingyou for being out of compliance with the CCPA.

 [ZG9]Linkto chart above.

 [ZG10]Linkto the “Sales and Sharing” sub-section above.