PRIVACY NOTICE

Cascade Energy California Residents Privacy Notice

CASCADE ENERGY, INC.®

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

This Privacy Notice for California Residents (this “Notice”) supplements the information contained in Cascade Energy, Inc.® (“Cascade,” “we” or “us”) Privacy Policy and applies solely to all visitors, users, job applicants, employees, and others who reside in the State of California (“consumers” or “you”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (the “CCPA”), as amended by the California Privacy Rights Act of 2020 (the “CPRA”) (together, the “California Privacy Laws”) and any terms defined in the California Privacy Laws have the same meaning when used in this Notice.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:

Publicly available information from government records.
De-identified or aggregated consumer information.
Information excluded from the California Privacy Laws’ scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and the California Confidentiality of Medical Information Act (“CMIA”), clinical trial data, or other qualifying research data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”) or California Financial Information Privacy Act (“FIPA”), and the Driver’s Privacy Protection Act of 1994.

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	YES
B. California Customer Records personal information, as listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES Please note that client payments may be collected through a third-party payment processor. We do not collect your payment data. *Asterisked data types are only collected from job applicants and employees, and, in some cases, only if voluntarily provided at the job applicant’s or employees discretion.
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES, but only if voluntarily provided by job applicants, employees, or users of our Energy Sensei® product through a user upload.
D. Commercial information.	Records of products or services purchased, obtained, or considered.	YES
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES, but this information is anonymized and cannot personally identify you.
G. Geolocation data.	Physical location or movements.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	YES, but only for job applicants and employees.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

How We Collect Your Personal Information

We obtain the categories of personal information and Sensitive Personal Information (defined below):

Directly from you, such as from forms you complete or products and services you purchase.

Indirectly from you, such as from observing your actions on our websites.
From third-parties utility companies, if you are a customer of such utilities.

Use of Your Personal Information

We retain your information for as long as required by applicable law, or for as long as is necessary for a business purpose (as disclosed in this Notice), whichever is longer. We may use or disclose your personal information we collect for one or more of the following purposes:

To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
To provide, support, personalize, and develop our websites, products, and services.
To create, maintain, customize, and secure your account with us.
To process your requests, purchases, transactions, and payments and prevent transactional fraud.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To personalize your website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our websites, and via email or text message (with your consent, where required by law).
To help maintain the safety, security, and integrity of our websites, products and services, databases, other technology assets, and business.
For testing, research, analysis, and product development, including to develop and improve our websites, products, and services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the California Privacy Laws.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our [Website users/consumers] is among the assets transferred.
To process your employment application;
To assess your capabilities and qualifications for a job;
To conduct reference checks;
To respond to your inquiries and communicate with you about your employment application, and to send you information regarding changes to our terms and policies;
To comply with or monitor compliance with any applicable law or regulation;
To conduct background checks if we offer you a position of employment; and
To preserve our other legitimate interests, for example, for administrative purposes, aggregate management reporting, internal training, and as generally required to conduct our business.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We do not sell personal information. We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed personal information for a business purpose to the following categories of third parties:

Payment processors (for payment transactions).
Cloud service providers (for cloud storage and computing services for data hosting and processing).
Website development and maintenance partners (for designing and maintaining our services).
Internet service providers (for internet connectivity, enabling online access, and data transfer).
Hosting service providers (for space and infrastructure for hosting our services, databases, and other digital assets).
Operating systems and platforms (for content integration and user experience).
Website analytics providers (such as Google Analytics, WordPress, and Amazon Web Services, for tracking and analyzing user behavior).
Marketing and advertising service providers (for marketing campaigns, including digital advertising and email marketing).
Email and communication service providers (for email marketing, customer support, and other communication channels).
Customer support and helpdesk tools (for providing customer support, including ticketing services).
Information and security service providers (for protecting your data and our system’s infrastructure).
Survey and feedback services (for customer feedback and to conduct surveys).

Sensitive Personal Information

Sensitive personal information (“SPI”) is a subtype of personal information consisting of specific information categories. In particular, we may have collected the below categories of SPI from you within the last 12 months. While we collect information that falls within the SPI categories listed in the table below, California Privacy Laws do not treat this information as sensitive because we do not collect or use it to infer characteristics about a person. We only use SPI for the specific business purposes identified in the following chart.

SPI Category	Specific Business Purpose(s)	Collection and/or Disclosure Details
Government identifiers, such as your Social Security number, driver’s license, state identification card, or passport number.	To assess your qualifications for a job. To process your employment with us, including to conduct background checks. To comply with or monitor compliance with any applicable law or regulation, or to respond to law enforcement requests or court order as required by applicable law.
Precise geolocation, such as your physical location within a small area (1,850 feet radius).]	To inform our weather data for energy use modeling purposes.	We only collect this information from Energy Sensei users that opt-in to such data collection. We never sell this information, and may only share it for the business purposes provided in this Notice.
Racial or ethnic origin.	To comply with federal and state equal opportunity laws. To design, implement, and promote our diversity and inclusion programs. To perform workforce analytics, data analytics, and benchmarking. To conduct internal audits and investigate complaints, grievances, and suspected violations of our policies. To respond to law enforcement requests, court order, or governmental regulations, as required by applicable law. To exercise or defend the legal rights of Cascade and its employees, customers, contractors, and agents.	We may collect this information only if voluntarily provided (for example, through a job application or content you choose to upload or otherwise disclose to us). We never sell this information, and may only share it for the business purposes provided in this Notice.
Religious or philosophical beliefs.	To review and process religious reasonable accommodation requests. To conduct internal audits and investigate complaints, grievances, and suspected violations of our policies. To respond to law enforcement requests, court order, or governmental regulations, as required by applicable law. To exercise or defend the legal rights of Cascade and its employees, customers, contractors, and agents.	We may collect this information only if voluntarily provided (for example, through a job application or content you choose to upload or otherwise disclose to us). We never sell this information, and may only share it for the business purposes provided in this Notice.
Health information.	To investigate and process workers’ compensation claims. To process health insurance claims. To conduct and process employment testing, including drug testing upon hire and as necessary afterward. To respond to law enforcement requests, court order, or governmental regulations, as required by applicable law.	We may collect this information only if voluntarily provided (for example, through a job application or in the course of employment). We never sell this information, and may only share it for the business purposes provided in this Notice.
Sex life, or sexual orientation information.	To process health insurance claims. To ensure equal access to health programs and equal family leave policies. To respond to law enforcement requests, court order, or governmental regulations, as required by applicable law.	We may collect this information only if voluntarily provided (for example, through a job application, in the course of employment, or through content you choose to upload). We never sell this information, and may only share it for the business purposes provided in this Notice.

Your Rights and Choices

The California Privacy Laws provide you with specific rights regarding your personal information. This section describes your California Privacy Law rights, and explains how to exercise those rights.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity (See Exercising Your Rights to Know or Delete), we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting [or selling] that personal information.
The categories of third parties with whom we share that personal information.
If we disclosed your personal information for a business purpose, identifying the personal information categories that each category of recipient obtained.
The specific pieces of personal information we collected about you (also called a data portability request).

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or de-identify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request by either emailing us at CEPrivacyOfficer@cascadeenergy.com or calling us toll-free at 1.866.321.4573 and ask to speak with our privacy staff.

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

You do not need to create an account with us to submit a request to know or delete.

We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

Response Timing and Format

We will confirm receipt of your request within 10 business days.

We endeavor to substantively respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

You do not need to create an account with us to exercise your opt-out rights. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

We will only use personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your California Privacy Laws rights. Unless permitted by the California Privacy Laws, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits consumers to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We only ever disclose such information to our subcontractors as a part of a specific program’s offerings. To request more information, please send an email to CEprivacyofficer@cascadeenergy.com.

Changes to this Notice

We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated notice on our websites and update the Notice’s effective date. Your continued use of our websites following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this Notice, the ways in which we collect and use your information described here, and our Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to email us at CEprivacyofficer@cascadeenergy.com.

Last Updated: May 8, 2024