Altus Privacy Policy
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.
For further information on how we process your personal data, please use the links below to jump to the listed section:
Last Updated: 2/2023
This notice describes the categories of personal information collected by Altus Power America Management, LLC (“Company”) and the purposes for which such information may be collected and used. For additional information about the Company’s data privacy practices, please review our Privacy Policy https://www.altuspower.com/privacy.
Identifiers and Contact information. This category includes names, addresses, telephone numbers, mobile numbers, email addresses, signatures, account names, dates of birth, bank account information, and other similar contact information and identifiers.
Protected Classification Information. This category includes characteristics of protected classifications under California or federal law.
Internet or Other Electronic Network Activity Information. This category includes without limitation:
Geolocation Data. This category includes, without limitation, geolocation data, including precise geolocation data from company-owned or employee mobile devices, application, or vehicles to ensure employee safety.
Audio, Electronic, Visual, Thermal, Olfactory, Or Similar Information. This category includes, for example, information collected from cameras, thermometers, and similar devices, and/or thermometers.
Biometric Information. This category includes the use of biometric equipment, devices, or software to record your time worked, to enter or exit facilities or rooms, to access or use equipment, or for other business purposes.
Professional and Employment-Related Information. This category includes, without limitation:
Educational Information. This category includes, without limitation, education history.
Sensitive Personal Information. This category includes sensitive information such as:
Inferences Drawn from the PI in the Categories Above. This category includes engaging in human capital analytics, including, without limitation, identifying correlations between certain characteristics and job success, analyzing data to improve retention, and analyzing employee preferences to inform HR policies, programs, and procedures.
Retention. We retain your personal information for as long as is necessary to determine your eligibility for a position with the company; manage compensation, benefits, and employment-related expenses; manage professional development, performance, and conduct; protect the company against illegal activity and other misconduct; undertake activities to verify and maintain the quality, safety, and performance of our products and services; and other routine business purposes and in accordance with the Company’s data retention schedule. We may retain your personal information for longer if it is necessary to comply with our legal or reporting obligations comply with a civil, criminal, or regulatory inquiry, investigation, subpoena or summons by federal, state, or local authorities, cooperate with law
enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local law, otherwise exercise or defend legal claims or as permitted or required by applicable law. We may also retain your personal information in a deidentified or aggregated form so that it can no longer be associated with you. To determine the appropriate retention period for your personal information, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we collect or process your personal information; and applicable legal requirements. Personal information does not include certain categories of information, such as publicly available information from government records, and deidentified or aggregated consumer information.
Disclosure. To carry out the purposes outlined above, the Company may disclose personal information to service provides or other third parties, such as background check vendors, third-party staffing vendors, and information technology vendors, outside legal counsel, and state or federal governmental agencies. The Company does not sell or share, as those terms are defined under applicable law, the above categories of personal information. The Company may add to the categories of personal information it collects and the purposes for which it uses information. The Company will inform you in the event it does so.
California Resident Individual Rights Requests. Individuals who are residents of the State of California have certain individual rights, which are outlined below.
Right To Know About Personal Information Collected or Disclosed. As a California resident, you have the right to request additional information, beyond that disclosed above, regarding the following, to the extent applicable:
Upon receipt of a verifiable request to know, and as required by applicable law, we will provide a response to such request.
Right To Request Deletion of Your Personal Information. You have the right to request that we delete the personal information we collected or maintain about you. Once we receive your request, we will let you know what, if any, personal information we can delete from our records, and will direct any service providers and contractors to whom we disclosed your personal information to also delete your personal information from their records.
There may be circumstances where we cannot delete your personal information or direct service providers or contractors to delete your personal information from their records. Such instances include, without limitation, when the information at issue is maintained: (a) to enable solely internal uses that
are reasonably aligned with your expectations based on your relationship with the Company and compatible with the context in which you provided the information, or (b) to comply with a legal obligation.
Upon receipt of a verifiable request to delete, and as required by applicable law, we will provide a response to such requests.
Right to Request Correction. You have the right to request that the Company correct any inaccurate personal information we maintain about you, taking into account the nature of that information and purpose for processing it. Upon receipt of a verifiable request to correct, and as required by the CCPA, we will provide a response to such requests.
Right to Non-Discrimination for the Exercise of Your Privacy Rights. We will not discriminate or retaliate against you for exercising any of the rights described above.
Submitting CCPA Rights Requests. To submit a CCPA Rights request as outlined above, please contact the Company’s Legal Department by calling us at 203-698-0090 or emailing us at legal@altuspower.com. We reserve the right to only respond to verifiable consumer requests to know, delete, or correct that are submitted as instructed.
Spouses, Dependents, and Associates. If you have knowledge that the Company collected personal information related to your spouse, dependent, or associate, please share a copy of this notice with all such individuals.
We reserve the right to amend this notice at any time without advance notice. Please direct questions about this notice you may call the Talent Management Team at 203-340-8408 or email at Talent.Management@altuspower.com.
Last Updated: March 2023
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”).
The personal data we collect in order to offer our services includes your:
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:
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.
We 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, our service providers, and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes. We may send you Altus Power-related direct marketing communications as permitted by law, including by email and text messages. You may opt out of our marketing communications as described in the opt-out of marketing section below. We (including our service providers on our behalf) may also engage in door-to-door marketing activities from time to time.
We provide our customers, as well as individuals referred by our customers, with the opportunity to opt out of having their information used for purposes not directly related to placement, processing, fulfillment, or delivery of a product or service. To opt out of marketing communications or to request to be added to our Do Not Call List or Do Not Mail List, you may use one of these convenient methods:
We also process personal data for the following business purposes because we have a legitimate interest in doing so:
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.
We may share your personal data with service providers who act on our behalf in order to more effectively deliver our advertising and to measure the effectiveness of our advertising. We will not share your personal data with third parties for their own marketing purposes. 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.
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.
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.
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).
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.
(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:
• Google Chrome
• Firefox
• Safari
• Internet Explorer
• Microsoft Edge
In addition to the browser-based controls, you can manage third party cookies by visiting www.aboutads.info/choices/ and www.youronlinechoices.eu/.
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.
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.
2200 Atlantic St Floor 6
Stamford, CT 06902
Attention: Altus Legal
Email: legal@altuspower.com
Altus may provide you the opportunity to participate in surveys or sweepstakes. If you participate, we will request certain personally identifiable information from you. Participation in these surveys or sweepstakes is completely voluntary and you therefore have a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and shipping address), and demographic information (such as zip code). We use this information to notify contest winners and award prizes. Altus may post the name(s) of the winners of any sweepstakes on its social media sites.