Privacy Policy

Altus Power Inc.

Altus Privacy Policy

Effective Date: February 12, 2024

ALTUS POWER (“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.

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

  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

1. Data We Collect

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;
  • 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;
  • Lead enrichment data, third party login data, information about people’s interactions with you on social media;
  • Demographic information, other information and inferences based on data that you provide to us; and
  • Any other data that you provide to us.

Some information may be required to subscribe to our Services.

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.

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 subscriber agreements, to provide troubleshooting and customer support services, for user authentication and security purposes, and to create a usage report and log foreach 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 the following 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. 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

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.  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 ("Matched Ads") by us uploading a customer list to a technology service or incorporating a pixel from a technology service into our own Services, and the technology service matching common factors between our data and their data. For instance, we in corporate the Facebook pixel on our Services and may share your email address with Facebook as part of our use of Facebook Custom 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 website on our website via the "Contact Us" page, 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 Targeted Advertising.

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 manage your cookie settings via the cookie manager modal on our website and following the instructions. For non-cookie based information, you may request on our website via the "Contact Us" page.

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 "Do Not Track" signals or other mechanisms, except as otherwise provided herein. For more information on "Do Not Track," visit 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 www.aboutads.info/choices , or the NAI opt-out at 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 on our website via the "Contact Us" page.. 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, or compliance with, any opt out options or programs, or the accuracy of any company statements regarding their opt out options or programs.

Do Not Track Signals

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

Mobile App Notifications. Our mobile app may send you notifications. If you do not wish to receive notifications, you can turn them off via your device settings.

Your Marketing Choices. We and our vendors, including our third-party advertising partners, may collect and use your data 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. 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 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 hello@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 Consumer Privacy Notice (“Notice”) supplements the Privacy Policy above and applies solely to California residents. The California Consumer Privacy Act (as amended, “CCPA”) requires us to provide you with certain additional information about how we collect, use, and disclose your “personal information” (as defined in the CCPA) that we collect online and offline. In this Notice, where we use a term in “quotes,” we are referring to the meaning of that term in the CCPA.

A.  Categories of Personal Information We Collect, Use, Disclose, and Retain

Throughout this Privacy Policy, we discuss in detail the specific pieces of personal information we collect, the sources of that information, and how we disclose it. Under the CCPA, we also must provide you with the "categories" of personal information and sensitive personal information we collect and disclose for “business or commercial purposes”.

As described further in the Privacy Policy above, the following table provides information about our practices in the 12 months leading up to the effective date of this Privacy Policy in relation to the categories of personal information that we generally collect from California and Colorado residents, the purposes for which we use the information, and the categories of other parties to whom we disclose personal information for a business purpose.

As used below, unless otherwise specified, “Perform our contract with you” includes the following uses of personal information as listed above: to provide you with the Services, to set up and maintain customer accounts, for accounting and invoicing purposes, to manage contracts, orders, and subscriber agreements, to provide troubleshooting and customer support services, for user authentication and security purposes, and to create a usage report and log for 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 prior employers, background check vendors, social media
Your use of the Services and other interactions with us
Affiliates 
Pre-employment  background checks
Evaluation  for employment, safety purposes, internal investigations
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 theServices 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
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 complaintsEnforce 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 (IP addresses)
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
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 personal information as described in the “Retention of Data” section above.

We collect account login information (username and password), which under the CCPA is “sensitive personal information.” The CCPA provides you with the right to limit certain uses of sensitive personal information. However, we do not use this information for purposes that you can limit.

B.  California Consumer Privacy Rights

If you 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).
  • Provide access to and/or a copy of certain personal information we have about you.
  • Delete certain personal information we have about you.
  • Correct inaccurate personal information that we have about you.
  • Opt out of the “sale” and “sharing” of your personal information (see the section below titled “‘Sales’ and ‘Sharing’”).

You may have the right to receive information about the financial incentives that we offer to you, if any. You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights.

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

To submit a request for yourself or as an authorized agent on behalf of a consumer, email us at hello@altuspower.com or call 1-888-88-ALTUS. We will take steps to verify your identity before complying with your request. If you have an account with us, we may verify your identity by requiring you to sign into your account. If you do not have an account with us, 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. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

C. “Sales” and “Sharing”

The CCPA places certain obligations on businesses that “sell” or “share” personal information for purposes of “cross-context behavioral advertising”, as defined in the CCPA. Our disclosure of personal information to third parties for purposes of analytics and certain types of advertising is considered a “sale” of personal information or the “sharing” of personal information for purposes of “cross-context behavioral advertising.” We do not knowingly “sell” or “share” the personal information of children under 16.

In the 12 months leading up to the effective date of this Privacy Policy, we have “sold” or “shared” – under the CCPA’s definition of these terms – the following categories of personal information: identifiers, Internet or other electronic network activity information, commercial information.

You have the right to opt out of “sales” and “sharing” of personal information. Please submit your request here: Your Privacy Choices.

Please note that we also respond to and abide by opt-out preference signals sent through the Global Privacy Control. Any opt out preferences you have exercised through these methods will only apply to the specific device/browser on which you made them. For more information on how to use the Global Privacy Control, see www.globalprivacycontrol.org

D.  California “Shine the Light” Disclosure

Under California’s “Shine the Light” law gives residents of California, under California Civil Code § 1798.83, you have the right to opt out of our disclosure of certain categories of “personal information” (as defined in the Shine the Light law) to third parties for their marketing purposes. To make such a request, you may submit on our website via the "Contact Us" page. Please note that we do not disclose personal information to third parties for their own marketing purposes.

10. Supplemental Notice for Residents of Colorado

Residents of Colorado may click here to view more information regarding each category of personal information we process (including sensitive data (called “sensitive personal information” above)), the purposes for which we process each category and the categories of entities to whom the personal information is disclosed. Residents of Colorado may click here to view more information about the categories of personal information that are “sold” (as defined in Colorado law) or used for “targeted advertising” (as defined in Colorado law, defined as “sharing” by the CCPA). Please note that we do not engage in profiling that produces legal or similarly significant effects.

11. Children’s Privacy

We do not knowingly solicit or collect personal information (as defined in applicable law) from children under the age permitted by applicable law without parental consent. If you are a parent or guardian age and believe that your child disclosed information to us in a way that is prohibited by applicable children's privacy laws, please contact us on our website via the "Contact Us" page.

12. Third Party Sites

The Services may contain links to other sites, products, and services that are external and not 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 provided by, such other sites, products, and services. We encourage you to be aware when you leave Services and to review the privacy policies of any third-party websites or services, as you will be subject to their policies, rules, and terms.

13. Updates to Our Privacy Policy

This Privacy Policy may be updated periodically. We will post a notice on our Site 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. Updates to this Privacy Policy are effective immediately upon posting, and by continuing to use the Services after an update, you acknowledge and accept the updated Privacy Policy.

14. How to Contact Us

If you have questions about how Altus handles your 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 Digital

Email: hello@altuspower.com