Last Updated: December 13, 2021 Pursuant to the California Consumer Privacy Act of 2018 (the “CCPA”), this privacy statement provides details regarding the categories of Personal Information about California consumers that Enel Green Power North America, Inc., its subsidiaries, and its parent company, Enel North America, Inc., (collectively, “we” or “company”) have collected, used and disclosed in the preceding 12 months. This privacy statement applies to California residents from or about whom our company obtains Personal Information (collectively, “you” or “your”). This privacy statement may change from time to time. Please check this privacy statement periodically for updates. What is Personal Information? References to “Personal Information” in this privacy statement means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or California household, subject to certain exceptions provided under the CCPA. Categories of Personal Information Collected The categories of Personal Information our company has collected about you within the past 12 months are as follows: Internet or other electronic network activity information, such as IP address, cookie data, browsing history and interactions with our websites, applications, systems, and emails. Identifiers such as first name, last name, postal address, email address, account name, phone number, or other similar identifiers. Professional or employment-related information such as the name of your employer, your job title/function and business contact information. Characteristics of protected classifications under California or federal law such as age, gender and marital status. Information and documents regarding identity such as driver’s license, passport, and physical characteristics or description contained in such identification documents. Commercial information such as signature in agreements entered into with our company, financial details and payment information. Financial and tax information such as credit card number, bank account number, debit card number, invoicing information and information for tax form W-9, including social security number. Audio information captured in recorded calls or any voicemail messages you left with our company. Sources of Personal Information Personal Information about you is collected from the following sources: directly from you; our service providers, including software vendors, who collect your Personal Information on our behalf or who provide us with your Personal Information; and publicly available databases and social media platforms. Purpose for Collecting Personal Information Personal Information about you is collected by our company for the following purposes: to communicate with you; to fulfill the commercial transaction that we enter into with you, including to fulfill our contractual obligations under the transaction, provide our services, process payments and administer and manage our commercial relationship with you; to market our products and services and perform marketing activities, such as providing you with marketing materials or information about or related to our company, inviting you to events and webinars, inviting you to participate in ways to support our company and entering you in our company’s prize drawings; to detect, monitor and protect against any applicable security incidents; to undertake activities to improve our operations including employee trainings, audit functions and research; to conduct internal research for technological development and demonstration; to respond to your inquiries when you contact our company; to respond to law enforcement requests; to manage licenses, permits and authorizations applicable to the company’s business operations; and to exercise our legal rights and comply with applicable law and regulations, including to meet our tax, legal and regulatory obligations. No Sale of Personal Information Our company does not “sell” Personal Information about consumers, including the Personal Information of consumers under 16 years of age, and has not “sold” Personal Information about consumers in the past 12 months for purposes of the CCPA. Disclosure of Personal Information In the past 12 months, our company has disclosed and shared your Personal Information with third parties for a business purpose, such as to receive certain services and to comply with tax, legal and regulatory requirements. The categories of Personal Information about you that our company shared and disclosed to a third party for a business purpose are as follows: Internet or other electronic network activity information, such as IP address, cookie data, browsing history and interactions with our websites, applications, systems, and emails. Identifiers such as first name, last name, postal address, email address, account name, phone number, or other similar identifiers. professional or employment-related information such as the name of your employer, your job title/function and business contact information. Characteristics of protected classifications under California or federal law such as age, gender and marital status. Information and documents regarding identity such as driver’s license, passport, and physical characteristics or description contained in such identification documents. Commercial information such as signature in agreements entered into with our company, financial details and payment information. Financial and tax information such as credit card number, bank account number, debit card number, invoicing information and information for tax form W-9, including social security number. Audio information captured in recorded calls or any voicemail messages you left with our company. For each category of Personal Information identified above, the categories of third parties to whom we disclosed and shared your Personal Information are or may include: (i) our service providers and vendors, including marketing consultants and software vendors, that process your Personal Information on our behalf; and (ii) government, quasi-government and regulatory agencies and organizations requesting Personal Information with which our company needs to comply. Your Rights under the CCPA If you are a California resident, you have the following rights, subject to certain exceptions set forth in the CCPA: Right to Non-Discrimination You have the right to be free from discrimination by our company as a result of you exercising your rights under the CCPA. Right to Know You have the right to request that our company disclose certain information to you about our collection, use and disclosure of your Personal Information over the past 12 months. Specifically, once we receive and confirm your verifiable request (see Exercising Your Rights below), we will at your request 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 your Personal Information. · The specific pieces of Personal Information we collected about you. · The categories of Personal Information about you that our Company shared with other businesses or persons for a business purpose. · The categories of other businesses and persons with whom our company shared Personal Information about you for a business purpose. Right to Request Deletion You have the right to request that we delete any of your Personal Information that we collected from you, subject to certain exceptions. Once we receive and confirm your verifiable request (see Exercising Your Rights below), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies under the CCPA. We may deny your deletion request if retaining the Personal Information is necessary to: · Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you. · Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. · Debug to identify and repair errors that impair existing intended functionality. · Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law. · Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.). · Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the deletion of the information is likely to render impossible or seriously impair the research’s achievement, if you previously provided informed consent. · Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with our company. · Comply with a legal obligation. · Make other internal and lawful uses of that information that are compatible with the context in which you provided the information. Exercising Your Rights If you are a California resident, you can exercise these rights by submitting a request to our company by emailing or calling our company at: Email: dataprotectionoffice-northamerica@enel.com Phone: +1 (800) 359-6615 Exercising Your Rights via Authorized Agent To submit a request as an authorized agent on behalf of a California resident who wishes to exercise these rights, you may use the same submission methods provided above. As part of our verification process, we will request that you provide your contact information, relationship to the California resident, documentation verifying your identity and documentation showing that you are authorized to act as a representative of the California resident (such as a power of attorney or signed written authorization from the California resident). Verifiable Requests The CCPA requires our company to verify requests that we receive, and we may ask you to provide certain additional information in order for our company to verify your request in accordance with the CCPA. To submit a verifiable request, please include in your request: Description of your request with sufficient detail that allows our company to properly understand, evaluate, and respond to it. Sufficient information that allows our company to reasonably verify you are the person about whom we collected Personal Information or an authorized representative. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable request does not require you to create an account with us. We will use Personal Information provided in a verifiable request only to verify the requestor’s identity or authority to make the request. You may make a verifiable request to access your Personal Information only twice within a 12-month period. Response Timing and Format For verifiable requests made by California residents, we will endeavour to provide an initial response to the request within 10 days of receipt and will attempt to fulfill the request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will cover only the 12-month period preceding our receipt of a verifiable request. 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 useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable request unless it is excessive (in particular because of the repetitive nature of the requests) 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. Non-Discrimination Our company will not discriminate against anyone for exercising any of their rights under the CCPA or any information privacy or data protection law applicable to them. Unless otherwise permitted, we will not: Deny you goods or services; Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; Provide you a different level or quality of goods or services; or Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. Do Not Track Please note that we do not support “Do Not Track” browser settings at this time. Contact Information For any questions regarding our company’s privacy policies and practices, please contact us at: Email: dataprotectionoffice-northamerica@enel.com Phone: +1 (800) 359-6615 Assistance for Disabled Individuals Alternative formats of this privacy statement are available upon request to individuals with a disability. For assistance, please contact our company at: Email: dataprotectionoffice-northamerica@enel.com Phone: +1 (800) 359-6615
