Privacy Policy

ALTUS POWER, INC.

Effective Date: November 8, 2021

ALTUS POWER, INC. (“Altus”, “we”, “our”) respects your privacy. This Privacy Policy describes the types of personal data we collect from customers using Altus, how we use the personal data, and with whom we share it. We also describe the rights you may have and how you can contact us about our privacy practices.

Altus is responsible for the use of your personal data for the purposes described in this Privacy Policy – our contact information can be found in the “How to Contact Us” section.

If you are a California consumer, for more information about your privacy rights, please see the section of this Privacy Policy called “California Consumer Privacy Statement.”

For further information on how we process your personal data, please use the links below to jump to the listed section:

  1. Personal Data We Collect
  2. How We Use The Personal Data We Collect
  3. How We Share Personal Data
  4. Data Transfers
  5. How We Protect Personal Data
  6. Retention of Personal Data
  7. Your Rights
  8. Cookies
  9. Updates to Our Privacy Policy
  10. How to Contact Us
  11. California Consumer Privacy Statement

 

  1. Personal Data We Collect

The personal data we collect in order to offer our services includes your:

  • Name;
  • Contact information, including your address, phone number, and email address;
  • Account details, including password;
  • Financial details, including billing information; and
  • Company name.

If you do not provide the required information you may not be able to subscribe to this product.

In addition to this data, our website uses cookies and other technologies to function effectively. These technologies record information about your use of our website, including:

  • 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, plug-ins and add-ons;
  • 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.

We also may 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. We use Google Analytics to help us analyze your use of our website, diagnose technical issues and improve our website.

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 our Cookie Policy.

  1. How We Use the Personal Data We Collect

We use the personal data that we collect in order to 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. We process personal data for these purposes because we are required to do so in order to perform our contracts with customers.

We also process personal data for the following business purposes because we have a legitimate interest in doing so:

  • Maintaining customer account records, in order to administer our business;
  • Maintaining records relating to our customers, in order to administer our business;
  • Managing our customer relationships and communicating with our customers, in order to administer our business and to
  • update our customers about new features and services that we may offer;
  • Complaint handling and dispute resolution, in order to resolve any complaints raised by our customers;
  • Ensuring compliance with applicable Altus policies and procedures relating to our services, in order to ensure the
  • security of our services and monitor compliance with our Terms of Use;
  • Fraud detection and prevention, in order to ensure the security of our services and protect Altus and its users against
  • fraud; and
  • Carrying out analytics, in order to identify potential improvements to our services and to measure engagement with our advertising campaigns.

In addition to the purposes above, we also process personal data when we are required to do so by law, for example in order to maintain accounting records.

If you consent to you or us doing so, we will share your personal data with any other party for select marketing purposes, nor will we partners, such as Google and LinkedIn, in order to more effectively deliver our advertising and to measure the effectiveness of our advertising. We also may use certain other non-necessary cookies to collect your personal information, without as described in our policy on cookies, with your consent. Our policy on cookies is set forth below.

If we plan to use the personal data that you provide for other purposes, we will provide an additional updated privacy policy to you to describe the purposes for which we will use the personal data and our legal basis for doing so.

  1. How We Share Personal Data

We may share personal data with service providers that support the delivery of Altus, including payment processors, customer support service providers, online advertising providers, and other service providers that process personal data on our behalf. We may also share personal data with certain data partners that require it under their terms in order for us to allow access to their data, such as the UTP Plan, the Consolidated Tape Association, and other Premium Data Partners. We also share your personal data with other entities in the Altus group of companies for the purposes described in this Privacy Policy. We have legally binding agreements with all service providers under which they are required to use personal data only as necessary to perform services on our behalf and to implement appropriate data security and confidentiality obligations, in accordance with applicable law.

In addition, we may disclose personal data about you (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) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).

  1. Data Transfers

We may transfer the personal data that we collect about you to recipients in countries other than the country in which the personal data originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the personal data. When we transfer your personal data to recipients in other countries, we will comply with applicable legal requirements regarding providing safeguards for the transfer of personal information. These safeguards include entering into the European Commission’s Standard Contractual Clauses with counterparties, and/or ensuring that counterparties are certified under the EU-U.S. or Swiss-U.S. Privacy Shield Framework. Further information about data transfers may be obtained by contacting us as indicated in the “How to Contact Us” section of this Privacy Policy.

  1. How We Protect Personal Data

Altus maintains technical and organizational safeguards to ensure an appropriate level of security and confidentiality for your personal data, in accordance with our policies and applicable legislation.

  1. Retention of Personal Data

The time period for which we keep personal data depends on the purpose for which we collected it. In all cases we keep it for as long as necessary to fulfil the purposes for which we collected it. We will then delete the personal 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).

  1. Your Rights

Subject to applicable law, you may have the right to request access to and rectification of the personal data we maintain about you, or to request the restriction of the processing of your personal data or to object to that processing on grounds relating to your situation.

In addition, you may have the right to request erasure of your personal data from Altus’s systems in certain circumstances provided by applicable law. Where technically feasible, upon written request and verifiable identification, we will provide you with a copy of the personal data provided to us by you in a structured, commonly used, machine readable format. To exercise these rights, please contact Altus as indicated below. You may lodge a complaint with a data protection authority if you are not satisfied with our response.

  1. Cookies

(a) Information That We Collect Automatically

When you use our website, we or our third-party service providers may collect certain information by automated means, using technologies such as cookies, web server logs, web beacons (including tags and pixels), and JavaScript.

Cookies are files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings on your device. Your browser may tell you how to be notified when you receive certain types of cookies and how to restrict or disable certain cookies. Please note, however, that without cookies you may not be able to use all of the features of our website.

In conjunction with gathering information through cookies, our web servers may log information such as your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. The web server logs may also record information such as the address of the web page that referred you to our website and the IP address of the device you use to connect to the Internet. They may also log information about your interaction with our website, such as which pages you visit.

(b) Categories Of Cookies And Other Automated Technologies

  • Strictly Necessary Cookies

These cookies are necessary for our website to operate properly and facilitate your use of its features. Without these cookies, certain services cannot be provided. These cookies help us understand information, such as your session ID and other server authentication information. This category of cookies should not be disabled. If you use your browser settings to block them, we cannot guarantee your security or predict how our website will perform during your visit.

  • Analytics Cookies

These cookies collect information about how visitors interact with our website, such as what pages you visit and if any errors have occurred. The information is used to improve how our website functions. These cookies don’t collect information that identifies you but generate statistical data about your use of our website. We use Google Analytics. The service registers a unique ID that is used to generate statistical data on how visitors use our website. If you want to opt out of our use of Google Analytics please click here.

  • Functional Cookies

These cookies allow our website to remember choices you make and provide enhanced and more personal features. They can also be used to remember changes made to parts of our website that you can customise. We also work with the third-party service providers Stripe and Intercom, each of which uses certain cookies. You can find out more about the cookies used by Stripe here and by Intercom here.

  • Advertising Cookies

These cookies can help us provide more effective advertising on our website. For example, we might use a cookie to help prevent you from seeing the same advertisement multiple times or to measure how many times an advertisement is viewed or clicked on. We use services like Google Tag Manager and LinkedIn cookies for these purposes. You can find further information on those companies’ privacy policies here and here.

(c) Your Choices

You can manage cookies through your web browser. Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. You can find out how to do this for your particular browser by clicking “help” on your browser’s menu or by visiting www.allaboutcookies.org. Please note, however, that without cookies you may not be able to take full advantage of all our website features.

The following external links will explain how to manage cookies for the most common browsers:

In addition to the browser-based controls, you can manage third party cookies by visiting www.aboutads.info/choices/ and www.youronlinechoices.eu/.

  1. Updates To Our Privacy Policy

This Privacy Policy may be updated periodically to reflect changes in our personal data practices. We will post a notice on our website to notify you of any significant changes to our Privacy Policy and indicate at the top of the Privacy Policy when it was most recently updated.

  1. How to Contact Us

If you have questions about how Altus handles your personal data or would like to exercise your rights, please reach out by emailing or writing to us at:

Altus Power, Inc.

102 Greenwich Avenue

Greenwich, CT 06831

Attention: Altus Legal

Email

legal@altuspower.com

  1. California Consumer Privacy Statement

Last Updated: November 8, 2021

This California Consumer Privacy Statement (“Statement”) supplements the Altus Privacy Policy. It applies solely to California consumers and addresses personal information we collect online and offline. This Statement does not apply to Altus’s personnel or job applicants.

This Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).

  1. Notice of Collection and Use of Personal Information

We may collect (and may have collected during the 12-month period prior to the effective date of this Statement) the following categories of personal information about you:

    • Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, and other similar identifiers
    • Additional Data Subject to Cal. Civ. Code § 1798.80: credit card number, debit card number, and other financial information
    • Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
    • Geolocation Data: e.g. certain geolocation data may be collected to conduct security and anti-fraud checks
    • Employment Information: professional or employment-related information

We may use the categories of personal information listed above for the purposes described in the Altus Privacy Policy. In addition, we may use these categories of personal information for certain business purposes specified in the CCPA, as described in this table:

Purposes Categories of Personal Information
Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Online Activity; Geolocation Data; Employment Information
Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Online Activity; Geolocation Data; Employment Information
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Online Activity; Geolocation Data; Employment Information
Debugging to identify and repair errors that impair existing intended functionality Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Online Activity; Geolocation Data; Employment Information
Undertaking internal research for technological development and demonstration Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Online Activity; Geolocation Data; Employment Information
Undertaking activities to verify or maintain the quality or safety of a service that is owned or controlled by us, and to improve, upgrade, or enhance the service that is owned or controlled by us Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Online Activity; Geolocation Data; Employment Information
  1. Our Prior Collection, Use and Disclosure of Personal Information

We may have collected and used your personal information, as described in Section 1 above, during the 12-month period prior to the effective date of this Statement. For the personal information collected during that timeframe, we describe below: (a) the categories of sources from which we may have obtained the personal information, (b) the categories of third parties with whom we may have shared the information, and (c) the categories of personal information we may have disclosed for a business purpose.

    • Sources of Personal Information

We may have obtained personal information about you from various sources, as described below.

Categories of Sources of Data Collection Categories of Personal Information
Directly from you, such as when you visit our facilities, when you sign-up to receive communications from Altus, when you sign up for Altus services, when you contact us with a comment or question, when you participate in an event, conference or other activity sponsored by Altus, when you participate in a public consultation, opinion, survey, focus group or provide us with feedback regarding our services Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Online Activity; Geolocation Data; Employment Information
From monitoring tools, such as cookies that track your use of our websites Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Online Activity; Geolocation Data; Employment Information
Our affiliates Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Online Activity; Geolocation Data; Employment Information
Businesses that we are evaluating in connection with a potential investment or business opportunity Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Online Activity; Geolocation Data; Employment Information
Vendors (e.g., background check providers), advisors, referral partners and other business partners Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Online Activity; Geolocation Data; Employment Information
Recruiting agencies, social media network or publicly available sources Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Online Activity; Geolocation Data; Employment Information
    • Sharing of Personal Information

We may have shared your personal information with certain categories of third parties, as described below.

Categories of Third Parties Categories of Personal Information
Our affiliates Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Online Activity; Geolocation Data; Employment Information
Vendors, broker-dealers, advisors and others who provide services to us or on our behalf Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Online Activity; Geolocation Data; Employment Information
Professional services organizations, such as auditors and law firms Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Online Activity; Geolocation Data; Employment Information
Data partners, such as the UTP Plan, the Consolidated Tape Association, and other Premium Data Partners Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Online Activity; Geolocation Data; Employment Information
Government entities, including regulatory agencies and law enforcement Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Online Activity; Geolocation Data; Employment Information
Operating systems and platforms Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Online Activity; Geolocation Data; Employment Information
    • Sale of Personal Information

We do not sell your personal information.

    • Disclosure of Personal Information for a Business Purpose

We may have disclosed to third parties for a business purpose all of the categories of personal information about you listed in Section 1 above.

  1. California Consumer Privacy Rights

You have certain choices regarding your personal information, as described below.

Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, and disclosed about you during the past 12 months.

Deletion: You have the right to request that we delete certain personal information we have collected from you.

How to Submit a Request: To submit an access or deletion request for yourself or as an authorized agent on behalf of a consumer, email us at legal@altuspower.com. For questions or concerns about our privacy policies and practices, please contact us as described in the How To Contact Us section of our Privacy Notice.

Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you have an account with us, we may verify your identity by requiring you to sign in to your account. If you do not have an account with us and you request access to or deletion of your personal information, we may require you to provide any of the following information: email address; postal address; telephone number, or other information. In addition, if you do not have an account and you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

Additional Information: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.