Renova Energy Corp. California Consumer Privacy Policy

This Privacy Policy Statement applies to your interaction with Renova Energy Corp. as a prospective, current, or former Renova Energy Corp. customer, visitor, or business partner. It describes how Renova Energy Corp. collects, uses, shares, and protects personal information from and about you, along with choices you can make about such information. This Privacy Statement is not a contract and does not create any legal rights or obligations.

The California Consumer Protection Act

In 2018, California passed the California Consumer Protection Act, a measure that puts control of your data in your hands. This Act applies to any company doing business with persons residing in California.

Our complete CCPA Privacy policy is provided below, as are links to help California residents exercise their rights. Renova Energy Corp. has tools that allow you to easily submit CCPA requests. We ask that you review the policy(ies) below to understand how the law affects you and what rights you have when submitting requests.

What is the California Consumer Protection Act (CCPA)?

In 2018, California passed the California Consumer Protection Act (CCPA), a privacy-centric bill aimed at protecting the privacy of California consumers, effective January 1, 2020. This bill sets requirements for how businesses handle consumers’ Personally Identifiable Information (PII) and gives rights to consumers in controlling how that data is used. Renova Energy Corp. has always taken the privacy and security of customer data seriously and has implemented steps that empower you in compliance with the CCPA.

The CCPA requires that businesses disclose the following: how information is used and if/how it may be shared with third-party services; how the business’ website responds to “Do Not Track” signals from a web browser.

Consumers also have the right to not be discriminated against for exercising their rights under the CCPA.

The CCPA was recently amended by the CPRA.

What is the California Privacy Act, or CPRA?

In November of 2020, California voters approved Proposition 24, the CPRA, which amended the CCPA and added new additional privacy protections that began on January 1, 2023. As of January 1, 2023, consumers have new rights in addition to those above, such as:

• The right to correct inaccurate personal information that a business has about them; and
• The right to limit the use and disclosure of sensitive personal information collected about them.

Businesses that are subject to the CCPA have several responsibilities, including responding to verified consumer requests to exercise these rights and giving consumers certain notices explaining their privacy practices. The CCPA applies to many businesses, including data brokers.

The CPRA amends the CCPA; it does not create a separate, new law. The CPRA refines the definition of sensitive personal information by including social security numbers, biometric data, precise geolocation, and driver’s license numbers, among others. It adds new rights, such as the right to rectification and the right to limit the use and disclosure of sensitive personal information, and allows a private right of action in the event of a data breach. While the CCPA covers service providers, the CPRA includes “contractors” who receive consumer data for business purposes. The law also defines the sharing of personal information to include cross-context behavioral advertising even when no money is exchanged.

Notice to Consumers Doing Business with Renova Energy Corp. Outside of California

While the California regulations legally only apply to consumers in California, we have standardized this process and will honor requests made by consumers who have interacted with Renova Energy Corp. in any state where we do business in the U.S. We are committed to providing the same privacy protections to our customers and potential customers, whether in California or in other states where we do business within the U.S.

Details for how to submit California requests and detailed information on how we use consumer data outlined below also apply to any consumer located in the U.S.

What Information We Collect

What Information Does Renova Energy Corp. Collect?

We collect the following categories of personal information in order to provide products and services to you, to communicate with you, to enhance our products, services, and operations, and for other operational, legal, and compliance purposes.

We disclose all of the categories of personal information described under this section for business purposes, including fulfilling products, services, and transactions; facilitating customer communication and outreach; enhancing our products, services, and operations; and complying with legal, compliance, law enforcement, and security requirements. Examples of the types of vendors we disclose personal information to for these purposes include analytics and research vendors, installation, repair, and warranty service companies, order processing and fulfillment vendors, fraud prevention, legal, compliance, and risk management vendors, information technology vendors, financial institutions, and marketing and advertising vendors.

We may use your identification information, commercial information, online activities, geolocation information, audio/video, geolocation, sensitive personal information, and other personal information to provide products and services to you, such as:

• Provide and deliver products and services, fulfill your orders and transactions, and manage returns and exchanges
• Process, record, and track your purchases, payments, returns, warranties, and rebates
• Process payment
• Create and manage your account registrations or benefit or reward program enrollment, such as your Renova Energy Corp. account
• Conduct and administer contests, surveys, and sweepstakes
• Provide you with in-store navigation and mapping services and help you find store locations near you
• Fulfill benefits associated with your membership or other use of our products and services
• Identify and verify your identity when needed to provide you with products and services or access to our systems

We may use all of the categories of information described under this section to facilitate and tailor our outreach to you, such as:

• Communicate with you through various channels with transactional or promotional information, such as transaction confirmation and reminder, newsletters, coupons, and other messages
• Evaluate and respond to your requests, inquiries, and applications
• Administer programs for product reviews and surveys as submitted by you and other customers

We may use all of the categories of information described under this section to enhance our products, services, and operations, such as:

• Conduct research and internal analytics, develop new products and services, perform market research and data analytics, and analyze our products, services, websites, and applications
• Customize your experiences in our stores and online, including customized advertisements and offers
• Determine and manage the effectiveness of our advertising and marketing
• Administering our websites and applications, and perform accounting, auditing, billing, reconciliation, and collection activities

We may use identification information, commercial information, online activities, geolocation, and audio, electronic, video, image, and other personal information for legal, compliance, fraud prevention, and security purposes, such as:

• Comply with and enforce applicable legal requirements, industry standards and our policies and terms, such as our Terms and Conditions of Use
• Assist law enforcement and respond to regulatory inquiries
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity

We may disclose information about you (1) if we believe we are required to do so by law, regulation, or legal process, such as a court order or subpoena; (2) as we deem appropriate or necessary in response to requests by government agencies, such as law enforcement authorities or tax authorities; (3) when we believe disclosure is appropriate or necessary to protect the rights, property, or safety of Renova Energy Corp., our customers, or others, including to prevent physical, financial, or other harm, injury, or loss or to collect debt you owe; or (4) in connection with an investigation of suspected or actual unlawful activity.

We use your personal information for various business or commercial purposes, including fulfilling products and services, communicating with you, supporting and enhancing our business functions, and for other legal, compliance, and security purposes.

• Identification information that can be used to identify you, such as your name, alias, address, phone number, email address, payment information, signatures, or other identifiers. We may also collect online identifiers, such as your IP address, when you browse our websites or use our applications. We may collect government-issued ID for certain types of transactions, but please provide government-issued ID information only if we ask you to.
• Commercial information, such as products or services you purchased or considered purchasing.
• Online activity information, such as browsing history, search history, and other information, is collected when you interact with our websites, applications, and advertisements. We, and our third-party partners may also use analytics tools to collect information about your keystroke activity and rhythms, mouse movements, scrolling, and clicks when you use our websites or mobile applications.
• Geolocation data, including precise geolocation data if you allow our application to collect it for purposes such as helping you locate the nearest Renova Energy Corp. store or alerting our stores when you are on the way to pick up your orders, or for analytic purposes.
• Audio, electronic, video, or image information, such as audio or video recording when you call us, video monitoring when you come to our stores, or photos taken when we are working on your project to document progress or completion. When legally permitted, after detecting a security incident to investigate, we may also use image scan technology on images we previously captured of an individual(s) suspected of being responsible for a security incident to aid our investigation and prosecution.
• Professional or employment-related information, such as information about you as representatives of our customers and business partners, in connection with our services and the operation of our business, including business contact information, job title, company name, and office visitor access information, where applicable.
• Protected class information under state or federal laws, such as age, gender, and family status.
• Education information, such as when you respond to a customer survey.
• Inferences or preferences we learn or infer about you.
• Sensitive personal information, such as precise geolocation, race and ethnicity information, and payment card information. We use the information to provide goods or services you request (e.g., with your consent, we use precise geolocation to calculate your arrival time for in-store product pickup so the products are ready for you upon your arrival). We may also use the information so that we can provide relevant products or services to you. In addition, where permitted by law, we use the information to prevent, detect, protect against, or respond to security incidents, identity theft, fraud, and illegal activities.

We do not knowingly collect or disclose personal information from children under the age of 16 without parental or guardian consent. If a child under the age of 16 has provided us with personally identifiable information, we ask that a parent or guardian contact us so that the information can be deleted.

We reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including, without limitation, in the event of a reorganization, dissolution, or liquidation).

We may have collected the following categories of personal information from consumers within the last twelve (12) months:

Nature of Your Interaction With Renova	Categories of Data Collected
Visitors to Our Platform	If you visit our websites or interact with use via our Platform, we may collect the following categories of information about you:Identifiers such as your real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.Personal information described in the California Consumer Records Act, Section 1798.80, subdivision (e). This may also include your name, address, telephone number, and information as to your current employment.Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with our websites. Approximate geolocation data. For example, we may receive information about what city and state your device is located in when accessing our websites.Professional or employment-related information. For example, we may receive information as to which company you are employed with or affiliated with.
Customers	While providing services to clients or potential clients, we collect and use personal information about individual clients, employees, and business owners; as well as other parties who may have dealings with our clients in the context of transactions, investigations, or disputes. The sources of this personal information are our clients themselves, public websites, social media platforms, research services, subpoenas and discovery requests, and other third-party sources. The categories of information we may collect regarding our clients (depending on the nature of our representation) include:Identifiers, such as a real name, alias, postal address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.Any personal information described in the California Consumer Records Act, Section 1798.80, subdivision (e) (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, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information).Characteristics of protected classifications under California or federal law.Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement.Professional or employment-related information.Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99).Sensitive personal information.
Prospective Customers	With respect to prospective clients, readers of our published materials, viewers of our webinars, and attendees at our events, we may collect:Identifiers, such as a real name, alias, postal address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
California Job Applicants	With respect to CA job applicants or lateral partner applicants, we may collect:Identifiers such as your real name, alias, postal address, passport, work permit, visa, or other immigration documentation.Personal information described in the California Consumer Records Act, Section 1798.80, subdivision (e). This may also include your name, address, telephone number, and information as to your current employment.Characteristics of protected classifications under California or federal law.Professional or employment-related information, including CV, and information regarding relevant skills and experience.Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99).Sensitive personal information, such as social security number or other state identification number, race or ethnicity, immigration status, any special requirements (such as, or relating to, a disability or health issue.)Results of background checks, including references, qualifications, and, to the extent permitted by law, criminal background checks (unspent convictions.)
Visitors to Our Offices	With respect to visitors to our offices, we may collect:Identifiers, such as a real name, alias, postal address, email address.Additionally, the owners or managers of our office buildings may collect audio, electronic, or similar information on our visitors, such as CCTV footage that may be shared with us in certain circumstances, such as to help investigate and prosecute crimes.

For more information about how we retain your information, please see the “How We Protect Your Information/How We Retain Your Information” section below.

What Are the Sources of Personal Information?

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you or your representatives. For example, information that our clients provide to us related to their solar panel installations and solar energy services or registration information that attendees of our events provide at sign-up.
• Operating systems and platforms. For example, we collect information about your device’s interaction with our websites and applications.
• Our vendors. For example, we may receive personal information on our California hob applicants through a background check.

We may receive additional information voluntarily provided by you when requesting information about products and services offered by Renova Energy Corp. or participating in the sales process.

Why We Collect Your Information

Purposes for Collecting Personal Information From Consumers

We collect personal information to:

• Provide the information and/or solar energy services you request
• To operate, troubleshoot, and improve our offering of services
• Respond to your inquiries
• To understand how people use our services, including by generating and analyzing statistics
• Operate and improve online services
• Personalize online and offline content
• Market, advertise and assess the effectiveness of our events, promotional campaigns, publications, and services
• To send you newsletters, updates, marketing communications, and other information or materials that may interest you
• Maintain safety in our offices and combat illegal activities
• For internal administration, data analysis, billing, and detecting, preventing, and responding to actual or potential fraud, illegal activities, or intellectual property infringement
• Comply with legal obligations and to enforce our rights
• To host, store and otherwise process information needed for business continuity and disaster recovery

To evaluate or conduct a merger, reorganization, dissolution, or other sale or transfer of some or all of our assets, or similar corporate transaction or proceeding, in which personal information held by us is among the assets transferred.

How We Share Your Information

Disclosure of Personal Information

In order to fulfill the purposes identified above, we may partner with service providers. For example, we may partner with electronic communication partners to communicate with you and provide our online services to you. We may disclose your personal information to a service provider for a disclosed business purpose.  When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the service provider to both keep that personal information confidential and not use it for any purpose except performing the contract. Our agreements with our service providers shall impose similar terms with respect to information practices as set forth in this Policy, and will be not less protective than those imposed on Renova Energy Corp.

We share your personal information with digital advertising partners for purposes including online targeted marketing and measuring the effectiveness of such marketing. Certain digital advertising partners combine the information into a customer profile. We may also disclose your information to our business partners, who may use it for additional purposes relevant to our products or services (e.g., joint marketing, joint product or service offering).

See the section above “What Information We Collect” to see which Categories Of Personal Information We Have Shared In The Preceding 12 Months. This information may have been shared with the following Third Parties/Service Providers:

1. City and County Planning, Permitting, Accounting Building & Safety Offices
2. Electric Utilities
3. SunPower includes a lease and loan
4. Homeowners’ Associations
5. Engineering Firms: Design and Build Systems
6. IRS 1099 Forms for Customer Referral Programs
7. CRM (Internal Data and Project Management Platform)
8. ERP (Accounting and Procurement Software)
9. Data Management, Design and Communication Software Companies
10. Subcontractors

How We Protect Your Information/How We Retain Your Information

How Long Your Personal Information Will Be Kept

Renova Energy Corp. keeps a Consumer’s personal information as long as is necessary in order to conduct its business purposes as they relate to sales and marketing, permitting, planning, installation, service, and the various labor and material warranties extended by Renova Energy and the various manufacturers we work with in order to provide Solar Systems/Storage, Roofing and Solar Maintenance Services. Information gathered through the sales, lease, and loan contract processes, as well as our maintenance process, is retained only as long as necessary to perpetuate our business objectives.

Job Applicant information is held only as long as the applicant becomes employed with Renova Energy Corp. Once employed, employee information is retained up to seven (7) years after his/her/their employment with Renova Energy Corp. is terminated.

Our Use of Consumers’ Sensitive Personal Information

While the definition of “sensitive personal information” may differ from state to state, it may include information that reveals a consumer’s social security, driver’s license, state identification card, or passport number; certain financial account details allowing access to such account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; genetic data; as well as certain processing of biometric information, health information, and sexual life/orientation information.

We may collect and process sensitive personal information as part of our legal representation of our clients and in the content of employment or applications for employment. We do not disclose sensitive personal information to third parties without your express consent, such as for background check purposes. If we need to share sensitive personal information with background check service providers, we will do so pursuant to a data sharing agreement as required by the applicable law.

We share your personal information with unaffiliated entities (companies outside the Renova Energy Corp.) with your proper implied or express consent. Specifically, we share your personal information to conduct business with service providers and business partners, comply with legal requirements, and transfer our business.

We may disclose your personal information to companies that provide various services to us in areas such as installation, repair, warranty, order processing and fulfillment, information technology, marketing, customer service, data analytics, research and enhancement, fraud prevention, and legal, compliance, and risk management. These companies may need access to information about you in order to perform their functions, but we are generally not authorized to use the information we disclose to them for any other purpose.

In limited cases, we may disclose information about you to a third party, who may also use the information for their own specific purposes. For instance, we may provide your information to a supplier in connection with product warranty or safety issues, to a business partner who is jointly providing or promoting a product or service to you, or to a social media or online advertising technology company to serve tailored commercial information to you.

Information We Collect by Automated Means

We collect information by automated means, both online and offline. When you use our websites or mobile applications, Renova Energy Corp. and our partners may collect certain information by using Cookies and Other Similar Technologies. If you choose to connect your mobile device to our free in-store Wi-Fi, we may collect your device usage information. When you visit our store or call our customer care hotline, we may collect audio or video information.

As described under the “What Information We Collect” section, we collect identification information (e.g., your IP address, device ID, cookie ID, mobile advertising identifier, or pixel identifier), online activities, geolocation data, and audio, electronic, video, or image information via automated means.

Cookies and Other Similar Technologies

Cookies are small text files placed on your device to store data that can be recalled by a web server in the domain that placed the cookie. We use cookies and similar technologies for storing and honoring your preferences and settings when accessing and interacting with our websites, combating fraud, analyzing how our websites and applications perform, customizing advertisements, and fulfilling other legitimate purposes. We may also use “web beacons” to help deliver cookies and gather usage and performance data. Our websites may include web beacons, cookies, or similar technologies from third-party service providers.

You have a variety of tools to control the data collected by cookies, web beacons, and similar technologies. For example, you can use controls in your internet browser to limit how the websites you visit are able to use cookies and to withdraw your consent by clearing or blocking cookies.

We may allow certain third parties, such as data analytics or online advertising service providers, to collect your browsing activity on our websites and applications in a manner that may be deemed to involve the sale of personal information under applicable law.

Through our use of these third-party tools, we may have sold or shared with such third parties the following categories of personal information about our website and application users within the last twelve (12) months:

• Internet or other electronic network activity information

Depending on your state of residence, you may have the right to opt out of the sale and sharing of personal information. To exercise this right, please follow the instructions on our Do Not Sell or Share My Personal Information.

Information We Collect from Other Sources

• Identification information. We may collect your contact information from Renova Energy Corp.’s affiliates, acquired businesses, business partners, public sources, or other individuals, such as through “Refer a Friend” programs or if someone purchases a product and asks that it be delivered to you.
• Commercial information. We may obtain your commercial information, such as your purchase history, from Renova Energy Corp.’s affiliates, acquired businesses, or business partners.
• Inferences or preference information about you, protected class information under state or federal laws, sensitive personal information, professional or employment-related information, education background, and geolocation information. We may collect inferences or preferences about you from business partners, such as data analytics or survey vendors. We may use such information to conduct aggregated analyses of our customer composition, and we may collect your interest and preference information to recommend products or services that may interest you. We may also learn about your preferences from public sources, such as information you submit in a public forum (e.g., a customer review).

Information We Generate or Derive

• Inferences or preference information about you. We may generate or derive some information about you through manual or automated means based on other information we collect. For instance, we may analyze your information and infer your shopping preferences to provide tailored recommendations to you. We may also conduct analyses based on aggregated or de-identified information. We may connect information we collect about you from the means described above if we can identify you as a Renova Energy Corp. customer, so that we can provide a personalized experience regardless of how you interact with us.

Your Privacy Rights and Choices

Your Privacy Rights

California Residents

Under the regulations, California consumers may have the ability to exercise certain legal rights. The regulations require that businesses respond to all requests within 45 days, and these requests are as follows:

Right to Know: The consumer may have the right to know what personal information the business has collected about the consumer, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom the business discloses personal information, and the specific pieces of personal information the business has collected about the consumer.

You may also have the right to request that we transfer information about you to a third party. Once we receive and confirm your verifiable consumer request, 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.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, we would have two separate lists disclosing: sales, identifying the personal information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
• If requested by you, we will provide you with a copy of the personal information you provided to us in a structured, commonly used, and machine-readable format and/or transmit that data to a third party.

Right of Deletion: The consumer may also be able to request that any specific personal information be deleted. With the exception of specific types of data (outlined below under ‘What information is excluded from requests?’), these deletion requests must be fulfilled by Renova Energy Corp., and once a deletion request is fulfilled, we will have no access to any data that was previously available to us, which means that Right of Access requests cannot be fulfilled from that point forward. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

Right to Request Disclosure of Data Practices: The consumer may have the right to request disclosure of our business’ data collection and sales practices in connection with the requesting consumer, including categories of personal information we have collected, the source of information, our use of the information, and the categories of personal information disclosed or sold to third parties, as well as the categories of third parties to whom such information was disclosed or sold. Renova Energy Corp. does not sell or rent any personally identifiable information to any third party, partner, or entity.

Right to Opt-Out of the Sale and Sharing of Data: the right to opt-out of the sale or sharing of their personal information by us. Once we receive and confirm your verifiable consumer request, we will no longer sell or share your personal information. The regulations allow consumers to opt out of the sale of their data to third parties. Renova Energy Corp. does not sell or rent personal information to third parties. Because of this company policy, we do not provide a method to opt out of the sale of consumer data.

Right to Limit the Use or Disclosure of Sensitive Personal Information: the right to request that we limit our use of your sensitive personal information to that which is necessary to perform the services or provide the goods that you reasonably expect of us, with some narrowly tailored exceptions.

Rights Against Discrimination: We will not discriminate against or retaliate against you for exercising any of your privacy rights. In that regard, we will not take the following actions in response to your exercising of your privacy rights, unless permitted by the applicable laws:

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

How Do You Verify the Identity of Consumers Making Data Requests?

Protecting the data of consumers from fraudulent requests is the highest priority in Renova Energy Corp.’s regulatory compliance procedures. All verifiable consumer requests must be validated through strict measures to ensure that the individual submitting the request is the owner of the information in question. Confirmation methods may include, but are not limited to, the following:

• Verification of information that we have on record.
• Confirmation of identity using multiple communication methods.
• Providing physical identification.

Renova Energy Corp. will confirm and validate any and all requests made while protecting the personally identifiable information related to the request itself. If we are unable to validate and confirm the identification of the individual submitting a verifiable consumer request, Renova Energy Corp. is legally obligated and reserves the right to deny that request.

Authorized Agents

Only you or a person that you or your employer authorize to act on your behalf may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may use an authorized agent to submit a privacy rights request on your behalf if you provide the authorized agent with written permission signed by you.

We may also require you to do either of the following:

(1) Verify your own identity directly with us.

(2) Directly confirm with us that you provided the authorized agent permission to submit the request.

We may deny a request from an authorized agent if the agent cannot provide to us your signed permission demonstrating that they have been authorized by the consumer to act on your behalf or if you do not confirm to us that you provided the authorized agent permission to submit the request.

The requirement to obtain and provide written permission from the consumer does not apply to requests made by an opt-out preference signal.

Response Timing and Format

We will acknowledge your request no later than ten (10) business days after receiving your request to delete, request to correct, or request to know and provide information about how we will process the request. The information provided shall describe, in general our verification process and when you should expect a response, except in instances where we have already granted or denied the request.

We shall respond to a verifiable consumer request within 45 calendar days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  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 the verifiable consumer request’s receipt.  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 usable and should allow you to transmit the information from one entity to another 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. For example, in cases where requests from a consumer are distinctly unsubstantiated or excessive, in particular because of their repetitive character, we may either charge a reasonable fee, in our discretion,  taking into account the administrative costs of providing the information or communication or taking the action requested, or refuse to act on the request altogether.

What Circumstances May Affect Renova Energy Corp.’s Requirement to Comply with a CCPA Request?

There are circumstances that exist that may limit or prevent Renova Energy Corp.’s ability and legal requirement to fulfill a Right of Deletion request. According to the regulations, a deletion request cannot be fulfilled for a Renova Energy Corp. customer where personally identifiable information is required for conducting ongoing business or fulfilling standing contractual obligations.

Renova Energy Corp. may also reject requests for Right of Deletion and Right of Access if reasonable steps have been taken to confirm the identity of the individual making that request yet are unable to determine that the request is being made by the owner of the personal data. This provision protects both consumers and companies from fraudulent and malicious requests by third parties.

The regulations have been interpreted to state that a Right of Deletion request implies that the individual is also opting out of any further use or collection of that data in the future. However, there may be situations where, in complying with a Right of Deletion request, Renova Energy Corp. would not be in possession of any data that would allow us to ensure that the information we receive or collect was subject to any requests made regarding that data previously. In the event that you believe we have come into possession of your data either directly or indirectly, please contact us to submit another Right of Access or Right of Deletion request.

If you have a question regarding requests involving Renova Energy Corp. that you believe may be affected by these provisions please contact us by sending an email to privacy@renovaenergy.com or by calling our dedicated toll-free phone number at 877-721-2518.

Is it Possible to Confirm that a Data Request to Renova Energy Corp. has been Fulfilled?

Yes. Renova Energy Corp. keeps an anonymized ledger of requests made so that any individual who has made a request, person or organization legally representing an individual who has made a request, or government entity can confirm and verify that a request was received and fulfilled. All confirmation inquiries are also subject to identity verification to ensure that the person or organization submitting a confirmation request is qualified to receive this information. The records of fulfillment are created using a method of one-way encoding for data that could be classified as PII, which allows us to log requests while remaining in compliance by not retaining any personally identifiable information.

How do I Opt Out of Select Services that Renova Energy Corp. Uses?

Renova Energy Corp. uses third-party services to help provide a better advertising experience for those interested in Renova Energy Corp. and/or the products and services that Renova Energy Corp. provides. If you would like to opt out of the Selling or Sharing of your personal information, please use this web form or contact us at privacy@renovaenergy.com or by calling our dedicated toll-free phone number at (877) 721-2518.

How to Submit Privacy Request(s)

How Do I Exercise My Rights?

Residents of certain states have rights to access, delete, correct, or opt-out from certain types of processing or sharing of their personal information. For your privacy and security, we will need to verify your identity for certain requests.

For information about how to exercise other privacy choices we make available to our customers, such as opting-out from email marketing or text messaging, please visit here *connect “How do I Opt Out of Select Services that Renova Energy Corp. Uses?”*

How to Contact Us

To exercise your rights described above, please submit a verifiable consumer request to us by either:

Phone:                       (877) 721-2518

Email:                         privacy@renovaenergy.com

Secure Form:            Click here

In compliance with the California regulations, Renova Energy Corp. provides more than one method to submit a request. Methods include calling our dedicated toll-free number, sending an email to our dedicated address, or submitting a request via a secure online form.

The online form simplifies the request process by allowing the individual making the request to provide information upfront that can help expedite its review and fulfillment.

However, we welcome communication via any method and will service all requests equally.

If you are ready to submit a request, please ensure that you are familiar with the information located here. If you have questions about making a request or would like more information, please call or email us for assistance.

You may be limited in the number of verifiable consumer requests for access or data portability in any given 12-month period (for example, twice per 12-month period for California residents). The verifiable consumer request must:

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

Before responding to your privacy rights request, we must verify your identity. We will do so by matching at least two reliable data points from your request to the information that we maintain about you. For certain more sensitive personal information, we may require further verification, including obtaining the consumer’s signed declaration under penalty of perjury, to further confirm that the requestor is the consumer. Once you contact us to exercise your rights, we will further guide you as to our verification process.