Last Updated: August 2, 2023
1. Personal information we collect
|Categories||Examples of Personal Information Uplight Collects||Processing Purpose|
|A. Individual Identifiers and Demographic Information||Contact information, such as first and last name, postal address, personal or business email address, company name and job title, account name, phone number, zip code, and Google Pay accounts.
Demographic information, such as age, date of birth, gender, marital status, education level, occupation, political affiliation, household income, and place of residence (for account verification purposes).
|B. Commercial Information||Account information, such as your log-in details, information that you store in your account, any preferences you set in your account, and other details about your use of the Services or Sites.
Survey responses, such as the information you provide in response to our surveys or questionnaires.
Communications, such as the information associated with your requests or inquiries, including for support, assistance, or order information, and any feedback you provide when you communicate with us.
Records of energy management devices and appliances, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
|C. Internet or Network Activity||Online activity information, such as the website you visited before browsing to the Sites or Services, pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
Device information, such as your computer or mobile device operating system type and version number, wireless carrier, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, and general location information such as city, state, or geographic area.
|D. Home Information||Information collected in connection with your home, building, or dwelling, such as images, square footage, age of the structure, any remodels or renovations, energy services received, service requests, type of heating/cooling systems, appliances present, number of adults and children in the home, and other home, building, or dwelling related information.||
|E. Energy Usage Information||Energy usage information from energy management systems, devices, or appliances.
|F. Inferences Drawn from Personal Information||Inferences regarding energy use, behavior, and attitudes toward green issues and technology.||
Unless we specifically request it, we ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Sites or Services, or otherwise to us.
We may also collect or create de-identified information from personal information in a manner that it cannot reasonably be used to infer information about, or otherwise be linked to, a particular individual. To the extent that we classify such information as “de-identified,” we commit to maintaining and using such information in a de-identified form and to not attempting to re-identify such information (except for purposes permitted by law).
Sources of Personal Information. We obtain the categories of personal information listed above from a variety of sources, including the following sources:
- Personal Information You Give Us: We receive the personal information you voluntarily submit to us, such as when you register and use your account with us, purchase home energy products, fill out a form on the Sites, participate in a survey, or otherwise communicate with us.
- Personal Information Automatically Collected: We, our service providers, and our advertising partners may automatically log, receive, or store certain types of information about you, your computer, or mobile device, and your activity over time when you use the Sites or Services and other sites and online services, such as the Internet and Network Activity Information described above. For example, we receive and store information about your use and activity on our Sites and within our Services. Uplight may collect some of this personal information automatically using cookies or other online tracking technologies, including for example:
- Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
- Flash cookies, or locally-stored objects, which are used on websites for purposes similar to cookies but allow storage of a larger amount of data.
- Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked, typically to compile statistics about usage of websites and the success of marketing campaigns.
- Local storage, which is used to save data on a visitor’s device. We use data from local storage to turn on web navigation, store multimedia preferences, customize what we show you based on your past interactions with our Sites, remember your preferences, and measure ad effectiveness.
- Session-replay technologies, which are third-party software used to record a video replay of users’ interactions with the Sites and Services. The video replay may include users’ clicks, mouse movements, scrolls, mobile app touches, typing, and other activity taken during the session. We use these replays for research and development purposes, such as to help us troubleshoot problems with the Sites and Services, understand how users interact with and use the Sites and Services, and identify areas for improvement.
- Personal Information from Devices and Appliances: We may receive and store energy usage information directly from your energy management system, devices, or appliances to create a profile of your energy usage (a “Home Energy Report”). For example, when you use a connected device, such as a smart thermostat or light bulb, we may collect information about your use of that device (including your settings on that device) and combine it with other information we receive about you to create a Home Energy Report. This might indicate, for example, the times at which your household energy use is at its highest or lowest.
- Personal Information from Your Utility Provider: We may receive and store certain personal information about you from your Utility Provider. For example, your Utility Provider may provide us with your historic energy usage information so that we may present more meaningful information to you and personalize Services in a meaningful manner.
- Personal Information Collected Offline: We may collect personal information when you attend a conference or Uplight event.
- Personal Information Obtained from Third Parties: We may receive personal information from third parties, such as our service providers, solutions partners, advertising partners, data analytics partners, operating systems and platforms, social media platforms, event sponsors, publicly available sources, and data licensors/providers. We may merge or combine such personal information with the personal information we collect from you directly, automatically, or through your devices and appliances or Utility Provider. For example, we may receive information from one of our data licensors about consumers, and use that information to provide additional insights to our Home Energy Reports.
Referrals: Users of the Services may have the opportunity to refer colleagues or other contacts to us and share their contact information. Please do not provide us with someone’s contact information unless you have their permission to do so.
2. HOW WE USE THE PERSONAL INFORMATION WE COLLECT
To Provide Our Products, Services, or Home Energy Reports. We use personal information to provide our Services and Sites and operate our business. This could include fulfilling your requests for products, Services, and Home Energy Reports. It could also include processing purchases or other transactions. For example, if you share your personal information to request a price quote or ask a question about our Services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product, service, or Home Energy Report, we will use such information to process your payment and facilitate delivery. We may also save your personal information to facilitate new product or service orders, or process returns, and to provide any surveys or other promotions you participate in.
Research and Development. We use personal information for research and development purposes, including to improve our products, Services, and Sites (such as by understanding and analyzing the usage trends and preferences of our users), diagnose technical issues, prevent fraud, and develop new features and functionality. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into such de-identified or anonymous data by removing information that makes the data personally identifiable to you. We may use anonymous data and share it with third parties for our lawful business purposes.
To Understand Your Interests. We use your personal information to personalize your experience with the Services and Sites, and to deliver information about Services relevant to your interests.
To Process Your Payment for Products and Services. We use personal information to facilitate payment for products and Services that you select through our Sites.
To Respond to Your Requests or Questions. We use personal information to provide you with support and to respond to your requests for customer support, including to investigate and address your concerns and monitor and improve our responses. This may also include responding to your feedback.
To Determine Your Eligibility and Set Up, Monitor, and Maintain Your Account. We use your personal information to verify your identity or determine your eligibility for some of our products, services, and promotions. For example, this may include verifying your age, date of birth, and place of residence. If you set up an account through the Services on any Site, we will use the registration information you provide in relation to that account creation to create, maintain, customize, and secure your account.
To Market Products or Services. We may send you Uplight-related or other direct marketing communications as permitted by law, including materials, updates, information, special offers, and promotional material. You may opt-out of our marketing communications as described in the “YOUR CHOICES” section below.
To Secure the Services and Sites, Fraud Prevention, and Safety. We use personal information as we believe necessary or appropriate to: (a) maintain the safety, security, and integrity of our Services, Sites, databases, and other technology assets; (b) protect our, your, or others’ rights, privacy, safety or property (including by making and defending legal claims); (c) audit our internal processes for compliance with legal and contractual requirements and internal policies; (d) enforce the terms and conditions that govern the Services; and (e) prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
As Required by Law. We use personal information as we believe necessary or appropriate to respond to subpoenas or requests from law enforcement or government authorities, and as required by applicable law, court order, or government investigation.
With Your Consent. We will disclose your personal information in accordance with your prior direction or, in some cases, we may specifically ask you for your consent to collect, use, or share your personal information, such as when required by law.
3. HOW WE SHARE THE PERSONAL INFORMATION WE COLLECT
Service Providers. To third party service providers (i.e., device manufacturers, website hosting providers, payment processors, log monitoring analysts, forensic data scientists, threat monitoring aggregators, user data analysts, marketing assistants, and other service providers for legitimate purposes permitted by applicable law) that provide services to us or that are necessary for the orderly operation of our business.
Other Users of the Services and the Public. Our Services and Sites may offer you the opportunity to create a profile and submit questions and comments that may be visible to other users of the Services and Sites. The information you provide in areas that are visible by other logged-in users of the Services and Sites may be read, collected, and used by others who access them. You can choose not to provide certain information, but that may limit your ability to take full advantage of the Services and Sites we provide. You may also be able to submit content to the Services (such as comments, reviews, photos, and videos), and such content may be made available to other users and public, or used in Uplight marketing materials, and we may identify you by displaying information such as your name, username, or social media handle along with the content you submit. We do not control how other users or third parties use any personal information that you make available to other users or the public.
Advertising Partners. We may also share personal information with third parties who we partner with for advertising campaigns or that collect information about your activity on the Services and Sites for the purposes described in the “Interest-Based Advertising” section above.
Professional Advisors. We may share personal information with persons, companies, or professional firms providing Uplight with advice and consulting in accounting, administrative, legal, tax, financial, debt collection, and other matters.
Business Transaction Participants. To third parties in connection with any merger, acquisition, consolidation, reorganization, divestiture, change in capital structure, sale or dissolution of all or part of the business, or any sale or transfer of assets of Uplight (including in connection with a bankruptcy or similar proceedings).
Authorities and Others for Legal Compliance, Fraud Prevention, and Safety. When we have a good faith belief that disclosure is necessary to comply with a legal obligation or for the purposes described above in the section titled, “Secure the Services and Sites, Fraud Prevention, and Safety.”
Law Enforcement. Under certain circumstances, we may be required to disclose personal information to law enforcement, government authorities, and other parties if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).
Consent. Otherwise with your express consent.
4. DATA RETENTION
5. SECURITY OF PERSONAL INFORMATION
We take reasonable steps to help protect your personal information in an effort to prevent loss, misuse, unauthorized access, disclosure, alteration and destruction. We follow reasonable standards to protect the personal information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage is 100% secure and we do not guarantee its absolute security. If you have any questions about the security of our Sites or Services, you can contact firstname.lastname@example.org. In the event that we are required by law to inform you of any unauthorized access or acquisition of your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
6. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
Users located in Europe can view more information about cross-border transfers in the section below titled “RESIDENTS OF THE EUROPEAN ECONOMIC AREA AND U.K.”
7. YOUR CHOICES
You can make the following choices regarding your personal information:
Promotional Emails. If you wish to unsubscribe from newsletters or marketing emails, follow the unsubscribe instructions included in these emails. If you decide not to receive promotional emails, we may still send you transactional communications, such as those about your account or to ask you to rate a Service you have requested.
Cookies. Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Services and our Sites may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.
Many of the opt-out preferences described in this section must be set on each device and/or browser for which you want them to apply. Please note that some of the advertising companies we work with may not participate in the opt-out mechanisms described above, so even after opting-out, you may still receive interest-based advertisements from other companies. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.
Access to Your Personal Information. We make reasonable efforts to allow you to make inquiries about the personal information we collect from you, and when appropriate we allow you access to your personal information for review and updating. You may request access to your personal information by contacting us as described below. We will grant you reasonable access to the data that we have about you as required by law.
Changes to Your Personal Information. We rely on you to update and correct the personal information contained in your account. If you have an account with us, you can control preferences regarding the use and disclosure of your personal information on your user profile. Note that we may keep historical information in our backup files as permitted by law. If our Sites do not permit you to update or correct certain personal information, please contact us as described below.
Deletion of Your Personal Information. You may request that we delete your personal information by contacting us as described below. We will grant a request to delete information as required by law, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes. Except as provided above, we will delete, aggregate, or de-identify all of your personal information as described in this subsection within the timeframes required by law.
Do-Not-Track. Some web browsers and devices permit you to broadcast the “Do Not Track” signal to help avoid being “tracked” online. At this time, the Sites do not respond to “Do not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
8. RESIDENTS OF CALIFORNIA
The information in this section applies only to residents of California. For purposes of this section, “personal information” has the meaning given in California privacy laws but does not include information exempted from the scope of those laws.
Also provided in that section are the specific business and commercial purposes for which we collect and use these categories of personal information. Such purposes are further described in the section titled, “HOW WE USE THE PERSONAL INFORMATION WE COLLECT.”
To the extent we collect sensitive personal information (as defined under California privacy laws), we only use or disclose it for purposes permitted under California privacy laws (e.g., to perform the Services and provide the Sites, detect security incidences and prevent fraud, and to verify and maintain the quality of the Services and Sites). We do not collect or use sensitive personal information for the purpose of inferring characteristics about California residents.
We do not knowingly “sell” or “share” the personal information of California residents under 16 years of age.
- Know/Access. You can request the following information about how we have collected and used your personal information:
- The categories of personal information that we have collected.
- The categories of sources from which we collected personal information.
- The business or commercial purpose for collecting, selling, or sharing personal information.
- The categories of third parties with whom we disclose personal information.
- A copy of the personal information that we have collected about you.
- Delete. You can ask us to delete the personal information that we have collected from you.
- Correct. You can ask us to correct inaccurate personal information that we maintain about you.
- Opt-out of sales/sharing. If we “sell” or “share” your personal information, you can opt-out. If you direct us not to sell/share your personal information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.
If you are a California resident and would like to exercise any of these rights, please submit your request as provided in the section below, “EXERCISING YOUR PRIVACY RIGHTS.”
9. RESIDENTS OF COLORADO, CONNECTICUT, UTAH, AND VIRGINIA
The following applies to residents of Colorado, Connecticut, Utah, and Virginia. For purposes of this section, “personal information” means “personal data” or “personal information” as such term is defined under applicable state privacy laws but does not include information exempted from the scope of such laws.
- the categories of personal information we process in “PERSONAL INFORMATION WE COLLECT;”
- the purposes for which we process personal information in “HOW WE USE THE PERSONAL INFORMATION WE COLLECT;” and
- the categories of personal information that we share with third parties and the third parties with whom we share this information in “HOW WE SHARE THE PERSONAL INFORMATION WE COLLECT.”
Your Privacy Rights. You may request the rights listed below and we will process the request in compliance with the applicable state privacy law. Please note, these rights are not absolute, and, in some cases, we may not be able to respond to your request, such as when a legal exemption applies or if we are not able to verify your identity.
- Access. You can request that we confirm whether we process your personal information and to access that personal information,
- Correct. You can ask us to correct inaccurate personal information that we maintain about you.
- Delete. You can ask us to delete personal information provided by or obtained about you.
- Port. You can request to obtain a copy of personal information that you have previously provided to us in a portable and, to the extent technically feasible, readily usable format.
- Opt-out of “sales” and “targeted advertising.” If we “sell” your personal information or engage in “targeted advertising” according to applicable state privacy law, you can opt-out.
If you are a resident of Colorado, Connecticut, Utah, or Virginia and would like to exercise any of these rights, please submit your request as provided in the section below, “EXERCISING YOUR PRIVACY RIGHTS.”
If we decline to take action on your request, you may appeal such refusal by contacting us at email@example.com within a reasonable time period after we send you our decision. We will process your appeal in compliance with the applicable state privacy law.
10. RESIDENTS OF NEVADA
11. RESIDENTS OF THE EUROPEAN ECONOMIC AREA
The following applies to individuals in the European Economic Area (EEA). For purposes of this section, “personal information” means “personal data” as such term is defined under EEA privacy laws but does not include information exempted from the scope of such laws.
Lawful bases for processing. Uplight is required to inform you of the lawful bases of our processing of your personal information, which are described in the table below. If you have questions about the lawful basis of how we process your personal information, contact us at the address listed in the section titled “ADDITIONAL INFORMATION” below.
|Processing Purpose||Lawful Basis|
||Processing is based on your consent. Where required by law, we rely on your consent. You have the right to withdraw it anytime in the manner indicated on the Sites or through the Services.
Processing activities constitute our legitimate interests. Where consent is not required by applicable law, we consider and balance the potential impact on your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent, or we are otherwise required to perform a contract or by law).
||Processing is necessary to comply with our legal obligations.|
||Processing activities constitute our legitimate interests. We consider and balance the potential impact on your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent, or we are otherwise required to perform a contract or by law).|
||Processing is necessary to comply with our legal obligations or constitute our legitimate interests.|
||Processing is based on your consent. Where required by law, we rely on your consent. You have the right to withdraw it anytime in the manner indicated on the Sites or through the Services.|
We will use your personal information only for the purposes for which we collected it, unless we reasonably determine we need to use it for another reason and that reason is compatible with the original purpose. For example, we consider deidentification, aggregation, and anonymization of personal information to be compatible with the purposes listed above and in your interest, because the deidentification, aggregation, and anonymization of such information reduces the likelihood of improper disclosure of that information.
Your Rights. European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
- Correct. Update or correct inaccuracies in your personal information.
- Restrict. Restrict the processing of your personal information.
- Object. Object to our reliance on our lawful basis as the basis of our processing of your personal information that impacts your rights.
- Delete. Delete your personal information.
When we receive your request, we may ask you to verify your identity before we can act on your request. We may withhold information where we are required by law to do so or if the search for that information would require disproportionate effort or have a disproportionate effect to, for example, the cost of providing the information, the time it would take to retrieve the data, or how difficult it may be to obtain the information requested.
If you are a resident EEA and would like to exercise any of these rights, please submit your request as provided in the section below, “EXERCISING YOUR PRIVACY RIGHTS.” If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection authority in your jurisdiction. In the EEA, you can find your data protection regulator here. In the United Kingdom, you can find your data protection regulator here.
Cross-Border Data Transfer. If we transfer your personal information to a country outside of the EEA such that we are required to apply additional safeguards to your personal information under EEA data protection laws, we will do so. Please contact us at the address listed in the section “ADDITIONAL INFORMATION” for further information about any such transfers or the specific safeguards applied.
12. EXERCISING YOUR PRIVACY RIGHTS
How to Submit a Request.
- Requests to know/access/port, delete, or correct. Please submit these requests by calling us toll free at 888-892-1550 or emailing us at firstname.lastname@example.org.
- Requests to opt-out of “sales” or “sharing/targeted advertising.” To opt-out of the sale of your personal information for the purpose of targeted advertising, please select the “Your Privacy Choices” link in the footer of the website and change your preferences. Note that due to technological limitations, if you visit our Services or Sites from a different computer or device, or clear cookies on your browser that store your preferences, you will need to return to this screen to select your preferences. Additionally, this webform will only opt-out your personal information from “selling” and “sharing” relating to the automatic collection of data on our Sites by cookies and similar technologies. To opt-out of other “sales,” we need to collect some identifying information. Please submit your request by phone or email using the contact information provided above.
No Fee Usually Required. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive.
What We May Need from You. When exercising your rights or otherwise assisting you, we may need to request specific information from you to help us confirm your identity and residence. This is a security measure to ensure we do not disclose personal information to any person who is not entitled to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
Time to Respond. We try to respond to all legitimate requests within 30 days of your request. Occasionally it may take us longer than 30 days to respond, for instance if your request is particularly complex or you have made a number of requests. In this case, we will notify you of the delay, and may continue to update you regarding the progress of our response.
No discrimination. You will not be subject to discrimination as a result of exercising the rights described herein. In some cases, when you exercise one of your rights, we will be unable to comply with the request due to legal obligations or otherwise, or we will be unable to provide you certain products or Services. These responses are not discrimination and our reasons for declining your request or ceasing Services will be provided at that time.
Authorized Agent. Where permitted by law, you may designate an authorized agent to make a request on your behalf. If you do so, we may require proof of your identification, the authorized agent’s proof of identification, and any other information that we may request in order to verify the request, including evidence of valid permission for the authorized agent to act on your behalf.
13. OTHER WEBSITES
15. ADDITIONAL INFORMATION
2530 Junction Place, Suite 200
Boulder, CO 80301