Privacy Statement

This Ecogy Energy Privacy Statement describes Ecogy Energies privacy practices, it describes how we collect, use, share and process information relating to individuals Personal Data. Please read this document to learn about your rights and choices regarding our processing of your Personal Data. 1. PROCESSING ACTIVITIES COVERED This Privacy Statement applies to the processing of Personal Data collected by us when you: Use our web or mobile applications or visit our public websites that display or link to this Privacy Statement; Communicate with us via email, slack, phone or text; Visit our branded social medial pages, Use our products and services as an authorized user where we act as a controller of your Personal Data; 2. RESPONSIBLE ENTITY Ecogy Energy is the controller of your Personal Data as described in this Privacy Statement, unless expressly specified otherwise. For the avoidance of doubt, this Privacy Statement does not apply to the extent we process Personal Data in the role of a processor on behalf of our customers, including where we offer to our customers various products and services through which our customers (and/or their affiliates): (i) create their own websites and applications running on our platform; (ii) sell or offer their own products and services; (iii) otherwise collect, use, share or process Personal Data via our products and services. 3. WHAT PERSONAL DATA DO WE COLLECT? We collect the following Personal Data directly from you: * If you express an interest in obtaining additional information about our services, request customer support, register to use our website or mobile applications then we may request and collect your name, phone number, email address. * If you create an account to use our services we will collect a username and password; * If you use and interact with our website, mobile applications or other services, we may collect information about your device and your usage of our services through cookies, log files or similar technologies, such as IP addresses or other identifiers, which may qualify as Personal Data; * If you voluntarily submit certain information to our services, we collect the information you have provided as part of that request; and If you provide us or our service providers with any Personal Data relating to other individuals, you represent that you have the authority to do so and acknowledge that it will be used in accordance with this Privacy Statement. Note: If you believe that your Personal Data has been provided to us improperly, or you wish to exercise your rights relating to your Personal Data, please contact us by using the information set out in the "Contact us" section below. 4. WHAT DEVICE AND USAGE DATA WE PROCESS We use common information-gathering tools, such as tools for collecting usage data, cookies, log files and similar technologies to automatically collect information that may contain Personal Data from your computer or mobile device as you navigate our site, use our services or interact with emails we have sent you. 4.1 DEVICE AND USAGE DATA We gather certain information automatically in connection with the use of our websites by individual users. This information may include IP address, device and application identification numbers, location, browser type, Internet service provider and/or mobile carrier, the pages and files viewed, searches, operating system and system configuration information and date/time stamps associated with your usage. This information is used to analyze overall trends, to help us provide and improve our website and to guarantee security and proper functioning. In addition, we gather certain information automatically as part of your use of our products and services. This information may include IP address (or proxy server), device and application identification numbers, location, browser type, Internet service provider and/or mobile carrier, the pages and files viewed, searches and other actions you take, operating system and system configuration information and date/time stamps associated with your usage. This information is used to maintain the security of the services, to provide necessary functionality, as well as to improve performance of the services, to assess and improve customer and user experience of the services, to review compliance with applicable terms of service, to identify future opportunities for development of the services, to assess capacity requirements and for security in general. Some of the device and usage data collected within our services could be personally identifying to you, although please note that this device and usage data is primarily used for the purposes of identifying the uniqueness of each user logging on. In some cases this information is required to identify an individual for security purposes or to provide specific services to our customers. 4.2 COOKIES AND OTHER TRACKING TECHNOLOGIES ON OUR WEBSITE We use cookies and similar technologies, to compile information about the usage of our website. When you visit our website, we or an authorized third party may place a cookie on your browser and/or device, which collects information, including Personal Data, about your online activities over time. Cookies allow us to track usage, determine your browsing preferences and improve and customize your browsing experience. We use both session-based and persistent cookies in our website and associated web applications. Session-based cookies exist only during one session and disappear from your computer when you close your browser or turn off your computer. Persistent cookies remain on your computer or device after you close your browser or turn off your computer. You can control the use of cookies at the browser level, but choosing to disable cookies may limit your use of certain features or functions on our websites and services. We use Google Analytics and Luck Orange. You can learn about Google’s or Lucky Orange's privacy practices by going to https://policies.google.com/privacy or https://classic.luckyorange.com/privacy.php respectively. Google Analytics and Lucky Orange both use cookies to help us analyze how our website is used, including the number of visitors, the websites from which visitors have navigated to our website, and the pages on our website visitors go to and how they use them. This information is used by us to improve our website and our web applications. 4.3 TELEPHONE LOGS AND EMAILS We also record information related to phone calls and emails within our Customer Relationship Management tools, this includes information such as phone numbers, email addresses, dates and times, durations, name and other such information that may be collected from emails or phone logs or during a call. 4.4 SOCIAL MEDIA Ecogy Energy social media pages such as LinkedIn, Instagram or Twitter include social media features where you may choose to post information about yourself or your activities. Your interactions with these social media features are governed by the privacy policies of the companies providing these features. 5. PURPOSES FOR WHICH WE PROCESS PERSONAL DATA We collect and process your Personal Data for the purposes and on the legal bases identified in the following: Providing our website, web applications and mobile applications and the associated services: We process your Personal Data to fulfill our obligations under applicable terms of service; we base the processing of your Personal Data on our legitimate interest to operate and administer our services to provide you with the content and services you request; Promoting the security of our website and services: We process your Personal Data by tracking use of our website and services, verifying accounts and activity, investigating suspicious activity and enforcing any applicable terms of service, to the extent this is necessary in promoting the safety and security of the services, systems and applications and in protecting our rights and the rights of others; Providing necessary functionality: We process your Personal Data to provide our services to you, we base this processing of your Personal Data on our legitimate interest to provide you with the necessary functionality required during your use of our website and services; Managing user registrations: If you have created an account with us, or we have created one at your request, we process your Personal Data by managing your user account for the purpose of providing our services to you according to any applicable terms of service; Handling contact and user support requests: If you request support via a web form or via other means including via email or phone, we process your Personal Data to fulfill your requests and to communicate with you; Developing and improving our website and services: We process your Personal Data to analyze trends and to track your usage of and interactions with our websites and services to the extent it is necessary for our legitimate interest in developing and improving our website and services; Assessing and improving user experience: We process device and usage data as described in Section 3 above, which in some cases may be associated with your Personal Data, in order to analyze trends in order to assess and improve the overall user experience to the extent it is necessary for our legitimate interest in developing and improving the service offering; Assessing capacity requirements: We process your Personal Data to assess the capacity requirements of our services to ensure that we are meeting the necessary capacity requirements of our service offering; Complying with legal obligations: We process your Personal Data when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Data to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our website, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes or to respond to lawful requests. Identifying customer opportunities: We process your Personal Data to assess new potential customer opportunities to the extent that it is in our legitimate interest to ensure that we are meeting the demands of our customers and their users’ experiences; Displaying personalized content: We process your Personal Data to conduct marketing research, provide personalized information about us on and off our websites and to provide other personalized content based upon your activities and interests to the extent it is necessary for our legitimate interest in advertising our websites or, where necessary, to the extent you have provided your prior consent (please see the "Your rights relating to your Personal Data" section, below, to learn how you can control how the processing of your Personal Data by New Black for personalized advertising purposes); 6. WHO DO WE SHARE PERSONAL DATA WITH? We may share your Personal Data with our contracted service providers, who provide services such as IT and system administration, hosting, analytics, marketing and customer support. 7. INTERNATIONAL TRANSFER OF PERSONAL DATA Your Personal Data will be collected, transferred to and stored by us in the United States and by our affiliates and third-parties disclosed in Section 6 above, some of whom may be based in other countries. We use reasonable means to ensure that your Personal Data is secure regardless of where it may be stored. The addresses of Ecogy Energy can be found below in the "Contact us" section. 8. CHILDREN Our websites and services are not directed at children. We do not knowingly collect Personal Information from children under the age of 16. If you are under sixteen, please do not submit any Personal Information to Ecogy Energy. If you are a parent or guardian and believe your child has provided Personal Information to us, please contact us, and we will endeavor to delete that information from our databases. 9. HOW LONG DO WE KEEP YOUR PERSONAL DATA? We may retain your Personal Data for a period of time, to meet the requirements presented in section 5 above. Generally we retain Personal Data to meet the functional needs of our products and services for which you, or a customer for whom you work, has signed up. For information on applicable data retention periods, please contact us using the information in the "Contact us" section, below. 10. YOUR RIGHTS RELATING TO YOUR PERSONAL DATA 10.1 YOUR RIGHTS You have certain rights relating to your Personal Data, subject to local data protection laws. Depending on the applicable laws and, in particular, if you are located in the European Economic Area, these rights may include: To access your Personal Data held by us (right to access); To rectify inaccurate Personal Data and, taking into account the purpose of processing the Personal Data, ensure it is complete (right to rectification); To erase/delete your Personal Data, to the extent permitted by applicable data protection laws (right to erasure; right to be forgotten); To restrict our processing of your Personal Data, to the extent permitted by law (right to restriction of processing); To transfer your Personal Data to another controller, to the extent possible (right to data portability); To the extent we base the collection, processing and sharing of your Personal Data on your consent, to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal. 10.2 HOW TO EXERCISE YOUR RIGHTS To exercise your rights, please contact us by using the information in the "Contact us" section, below. We will try to respond to all legitimate requests within four weeks and will contact you if we need additional information in order to honor your request. To discontinue your account or request return or deletion of your Personal Data and other information associated with your account, please contact us by using the information in the "Contact us" section, below. Some registered users may update their user profile settings and event registrations by logging into their accounts and editing their profile settings. 10.3 YOUR RIGHTS RELATING TO CUSTOMER DATA As described above, we may also process Personal Data submitted by or for a customer to our products and services. To this end, if not stated otherwise in this Privacy Statement, we process such Personal Data in the role of a processor on behalf of a customer (and/or its affiliates) who is the responsible controller of the Personal Data concerned. We are not responsible for and have no control over the privacy and data security practices of our customers, which may differ from those set forth in this Privacy Statement. If your data has been submitted to us by or on behalf of an Ecogy Energy customer and you wish to exercise any rights you may have under applicable data protection laws, please inquire with the applicable customer directly. This is because we can only access a customer’s data upon instruction from that customer, if you wish to make your request directly to us, please us with the name of the customer who submitted your data to us. We will refer your request to that customer, and will support them in responding to your request. 11. HOW WE SECURE YOUR PERSONAL DATA We take precautions including organizational, technical and physical measures to help safeguard against the accidental or unlawful loss, alteration and unauthorized disclosure of, or access to, the Personal Data we process or use. While we follow generally accepted standards to protect Personal Data, no methods are ever fully secure. You are solely responsible for protecting your password, limiting access to your devices and signing out of our website. If you have any questions about the security of our website, please contact us by using the information in the "Contact us" section, below. 12. CHANGES TO THIS PRIVACY STATEMENT We reserve the right to update this Privacy Statement from time to time to reflect changes in our practices. If we make a material update, we may provide you with notice prior to the update taking effect by posting a notice on our website or by contacting you using the email address you provided. 13. CONTACT US To exercise your rights regarding your Personal Data, or if you have questions regarding this Privacy Statement please email legal@ecogyenergy.com or send mail to: Data Protection Officer ECOGY ENERGY, 315 FLATBUSH AVE #393, BROOKLYN, NY, 11217, UNITED STATES.