The California Consumer Protection Act

Your Rights Under the California Consumer Protection Act

• What is the California Consumer Protection Act (CCPA)?
• What information does Renova Energy collect, and how is it used?
• What rights do I have under the CCPA?
• What information is excluded from CCPA requests?
• What information does Renova Energy collect, and why?
• What services does Renova Energy use that may relate to the CCPA?
• How do I submit a CCPA request to Renova Energy?

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 consumers rights to control how that data is used. Renova Energy has always taken the privacy and security of customer data seriously and has implemented steps that empower you in compliance with the CCPA.

Under the CCPA, consumers have the right to request access to information about the data we hold, a request that the data be deleted, a disclosure of our data collection practices and how the data is used, and a request to opt out of the sale of their data to third parties. Renova Energy does not and will never sell or rent the types of information outlined in this document.

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

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

Notice to consumers doing business with Renova Energy outside of California.

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

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

What information does Renova Energy collect, and how is it used?

Renova Energy collects both personally identifiable information (PII) and non-personally identifiable information when consumers contact us with interest in Renova Energy offerings and during the ensuing communications to service these requests. This data is stored for the purposes of communication, advertising, and providing agreed-upon or contracted delivery of products and services. We may, at times, share this information with trusted third parties for advertising and marketing purposes, services that we require to conduct regular business, or services that allow us to enhance the services provided to consumers both online and offline.

The information we may collect is as follows, and the specific information we collect from each person will depend on the types of interactions and communications that are chosen by that person. Some items below may not be individually considered personally identifiable information, but maybe when combined with other items.

• Full name
• Phone number
• Email address
• Physical address
• IP address
• Google Client ID (if available)

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

For more details on how your information is used on our website and online, please review our Privacy Policy (link)

How does the CCPA allow me to make requests regarding my personally identifiable information?

Under the CCPA, California consumers may have the right to make personal information requests, known as the “Right of Access” and “Right of Deletion.” The CCPA requires that businesses respond to all requests within 45 days, and these requests are as follows:

• Right of Access: The consumer may have the right to request and receive a list of personal information and additional details a business collects (or has collected), as well as the intended business use for collecting the data. A Right of Access request entitles a person to request the data collected for the previous 12 months no more than twice within that time period. Data provided by a Right of Access request is restricted from providing highly sensitive data such as social security numbers and banking information.
• 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 CCPA requests?’), these deletion requests must be fulfilled by Renova Energy, 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.
• 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 does not sell or rent any personally identifiable information to any third party, partner, or entity.
• Right to Opt-Out of the Sale of Data: The CCPA allows consumers to opt out of the sale of their data to third parties. Renova Energy does not and will never 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.
• Rights Against Discrimination: The consumer has the right to not be discriminated against for exercising their rights under the CCPA.

How do you verify the identity of consumers making CCPA requests?

Protecting the data of consumers from fraudulent requests is the highest priority in Renova Energy’s CCPA compliance procedures. All CCPA 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 will confirm and validate any and all requests made for both Right of Access and Right of Deletion requests 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 CCPA request, Renova Energy is legally obligated and reserves the right to deny that request. Requests must be made exclusively by the individual whose data is the subject of the request; the CCPA does not allow for other members of the household to request data on behalf of others within that household unless they are a legal parent or guardian of the minor for whom the request is being made. For the purposes of the CCPA, a minor is defined as a person 13 years of age or younger.

What circumstances may affect Renova Energy’s requirement to comply with a CCPA request?

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

Renova Energy 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, but we 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 CCPA has 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 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 that you believe may be affected by these provisions, please contact us by sending an email to ccpa@renovaenergy.com or by calling our dedicated toll-free CCPA phone number at (877) 721-2518

Is it possible to confirm that a CCPA request to Renova Energy has been fulfilled?

Yes. Renova Energy 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 CCPA requests while remaining in compliance by not retaining any personally identifiable information.

To create and maintain verifiable records, every request is recorded with the following information:

• An anonymized (salted or hacked) value for the methods used to communicate with the person making the request
• Date of the request
• Date of Renova Energy’s response
• Date of the request’s fulfillment
• Type of request made by the individual (Access, Delete, Lookup)
• Manner or method in which the request was made
• Type of response (accepted or rejected)
• Description and details of denial if the request is denied in whole or in part.
• Email address of the Renova Energy employee who worked to fulfill the request.

This information will be provided to a properly verified individual or organization in response to a request as described above. These confirmation requests will also be recorded.

How does Renova Energy secure and anonymize PII in their CCPA request ledger?

Renova Energy maintains ledgers that make use of salted or stored values for the contact information used to fulfill the request. This allows us to store a record of the transaction without requiring that we retain any personally identifiable information. When a value (such as an email address or phone number) is hashed, it cannot be “unhashed.” The result is an encrypted version of the original value. No two hashes are alike, and when the same original value is hashed again, it will always result in the same encrypted string.

By using this method, we are able to convert contact information to an encrypted string, delete the records we have, and, at a later date, provide a lookup of that record by re-hashing the information an individual provides and then searching for that anonymized value in our request logs. For reference, this secure method of data storage is how the passwords you use on websites and apps are stored and protected.

For more details on what hashing is and how it works, read more here: https://en.wikipedia.org/wiki/Hash_function

How do I opt out of select services that Renova Energy uses?

Renova Energy uses third-party services to help provide a better advertising experience for those interested in Renova Energy and/or the products and services that Renova Energy provides. These are listed below and provide for the ability to opt-out. The list provided below is not a complete list of all third-party services, and only those services that are affected by the CCPA are listed here. For a full list of third-party services that we use online, please refer to our Privacy Policy.

How do I submit a CCPA request to Renova Energy?

In compliance with the CCPA, Renova Energy provides more than one method to submit a CCPA request. Methods include calling our dedicated toll-free number, sending an email to our CCPA 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.

The Renova Energy dedicated CCPA phone number is:

(877) 721-2518

The Renova Energy dedicated CCPA email address is:

privacy@renovaenergy.com