OUR PRIVACY POLICY

Updated December 31, 2016

PALMco knows that your privacy is important to you, and we want you to know that it is important to us too. We created this PALMco Privacy Policy (“Privacy Policy”) to explain the types of information we collect through our PALMco-branded mobile application (the “Mobile Application”) and our website available at https://www.palmcoenergy.com (the “Website”), the ways in which we may use, disclose and protect such information once it is collected, and how you can opt out of some of our uses and disclosures of your information. By using the Website or Mobile Application, you agree to the terms of, and consent to the practices set forth in, this Privacy Policy, as it may be amended from time to time. “PALMco,” “we,” “us,” “our” and other similar pronouns mean, collectively, PALMco Power CT, LLC; PALMco Energy IL, LLC; PALMco Power IL, LLC; PALMco Energy MA, LLC; PALMco Power MA, LLC; PALMco Energy MD, LLC; PALMco Power MD, LLC; PALMco Energy NJ, LLC; PALMco Power NJ, LLC; PALMco Energy OH, LLC; PALMco Power OH, LLC; PALMco Energy PA, LLC; and PALMco Power PA, LLC

GENERAL PRINCIPLES. Here are a few general principles to keep in mind as you read through this Privacy Policy:

1.1. Website and Mobile Application Owners and Operators. The Website and Mobile Application are owned and operated by PALMco.

1.2. Updates. As our business and the Website and Mobile Application evolve this Privacy Policy may change, so check for updates to this Privacy Policy through the Website and Mobile Application periodically by clicking on the “Privacy Policy” link at the bottom of the Website or tapping on the “Privacy Policy” tab in the Mobile Application to make sure you understand how information about you and your use of the Website and Mobile Application will be treated.

1.3. Relationship to Website Terms of Use and Mobile Application EULA. This Privacy Policy is incorporated into, and a part of: (i) the Website Terms of Use, which can be viewed at https://www.palmcoenergy.com/terms-of-use/ (the “Website Terms of Use”) and (ii) the PALMco Mobile Application End User License Agreement, which can be viewed at any time in the Mobile Application by tapping on the “End User License Agreement” tab (the “Mobile Application EULA”).

1.4. Scope of Privacy Policy. This Privacy Policy applies only to information that you provide to us, or that we collect, through the Website or Mobile Application. It does not apply to information provided or obtained by any other means, such as over the phone, by mail or in person.

1.5. Third-Party Websites. The Website or Mobile Application may contain links, banners, widgets or advertisements that lead to websites owned or operated by third parties or enable you to view websites owned or operated by third parties within the Website or Mobile Application. We are not responsible for these websites, and their posted privacy policies (not this Privacy Policy) will govern the collection of your information through those websites and the use and sharing of that information. We encourage you to review the privacy policies of websites you choose to link to from the Website or Mobile Application or view within the Website or Mobile application so that you can understand how those websites collect, use and share your information.

2. WHAT INFORMATION DO WE COLLECT THROUGH THE WEBSITE AND MOBILE APPLICATION? We may collect both Personally Identifiable Information and Non-Personally Identifiable Information (each as defined below and referred to together as “Information”) about you and your usage when you access or use the Website or Mobile Application.

2.1. “Personally Identifiable Information” is information that can be used to identify you as an individual or enable someone to contact you, as well as information attributed with such information. Personally Identifiable Information that we collect from you through the Website or Mobile Application may include, for example, your username, password, name, PALMco account number, utility account number, billing address, service address, e-mail address, phone number, wireless device addresses (including text message addresses), date of birth, last four social security number (“SSN”) or tax identification number (“TIN”) digits or entire SSN or TIN. For example, we collect Personally Identifiable Information when you log in to the Website or Mobile Application, update your account profile on the Website or Mobile Application, sign up for our notifications, complete surveys, or submit a comment, question or other information to us through the Website or Mobile Application. Because engaging in these activities is completely voluntary, you have a choice whether or not to provide Personally Identifiable Information through the Website or Mobile Application.

2.2. “Non-Personally Identifiable Information” is any information that is not Personally Identifiable Information and may include, for example, information about the device on which you access, install and use the Mobile Application or the device, computer or software on which you access, view and use the Website, such as your IP address, browser type, domain names, access times, referring website addresses, operating system, network information, device identification number, unique numerical identifier that we create so we can recognize your device when it communicates with our server, and pages visited within the Website or Mobile Application. In some cases, your Non-Personally Identifiable Information may be linked to your Personally Identifiable Information.

2.3. Collection and Use of Your SSN or TIN. Although we typically collect only the last four digits of your SSN or TIN, in the event that we collect your complete SSN or TIN we will, in addition to taking the other measures described in this Privacy Policy with respect to Personally Identifiable Information to protect your complete SSN or TIN, protect your complete SSN or TIN by not doing any of the following: communicating your complete SSN or TIN, or otherwise making it available, to the general public; publicly displaying your complete SSN or TIN either within or outside our systems or facilities; intentionally printing or embedding your complete SSN or TIN on any card required for you to access products, services or benefits; requiring you to transmit your complete SSN or TIN over the Internet unless the connection is secure or your complete SSN or TIN is encrypted; requiring you to use your complete SSN or TIN to access an Internet website, unless a password or unique personal identification number or other authentication device is also required to access the Internet website; printing your complete SSN or TIN on any materials that are mailed (including facsimile and e-mail) unless required by law or on documents sent as part of an application, an amendment, or termination of the account, in which case the number may not be on a postcard or visible through an envelope; requiring use of your complete SSN or TIN as an ID number; displaying your complete SSN or TIN on any document intended to be recorded by a county recorder; or selling, leasing, loaning or otherwise intentionally disclosing your complete SSN or TIN to third parties without written consent from you.

3. USE AND SHARING OF YOUR INFORMATION.

3.1. Purposes. We collect and use your Information:

3.1.1. to operate the Website or Mobile Application and develop new features and offerings on the Website or Mobile Application;

3.1.2. to set up and deliver the services you have requested;

3.1.3. to customize the Website or Mobile Application to your interests and history with us;

3.1.4. to send you alerts that we are required by applicable law or regulation to give you the option to receive through the Website or Mobile Application;

3.1.5. to administer your account with us and send you notifications regarding your account with us or the services you receive from us;

3.1.6. to inform you of products or services available from us or promotions or programs that we offer, or send you other marketing or promotional communications, which you may opt out of receiving through certain methods by following the instructions in Section 4 below;

3.1.7. to respond to your requests, questions or concerns or otherwise communicate with you or provide customer service to you;3.1.8. to contact you, via e-mail or any other authorized method, with surveys to conduct research about, for example, your opinion of our current services or of potential new services that may be offered;

3.1.8. to contact you, via e-mail or any other authorized method, with surveys to conduct research about, for example, your opinion of our current services or of potential new services that may be offered;

3.1.9. to protect our rights and property, and recover debt and prevent fraud;

3.1.10. to conduct market research and generate general statistics regarding the use of the Website or Mobile Application; and

3.1.11. for other purposes disclosed when your Information is submitted to us.

3.2. Third Party Service Providers. We do not sell, rent or lease our customer lists to third parties. We occasionally hire other companies to provide services for us or on our behalf. We will only provide those companies the Personally Identifiable Information they need to deliver their services. They are required to maintain the confidentiality of your Personally Identifiable Information and are prohibited from using it for any purpose other than delivering their services for us or on our behalf. We will not distribute or disseminate your Personally Identifiable Information to any unaffiliated third party vendor other than such service providers without your prior consent.

3.3. Certain Uses and Disclosures Permitted by Law. Notwithstanding anything to the contrary herein, to the extent permitted by law we may:

3.3.1. disclose any Information collected through the Website or Mobile Application, or concerning the use of the Website or Mobile Application, to government authorities or third parties pursuant to a legal request, subpoena, or other process that requires disclosure of such Information;

3.3.2. use or disclose your Information to collect debts, fight fraud, reduce credit risk, protect the rights or property of us, our customers, our Website or Mobile Application, or third parties, or when we otherwise believe in good faith that the law requires it; and3.3.3. link your Non-Personally Identifiable Information, such as your IP address, with your Personally Identifiable Information when we feel that it is necessary to enforce compliance with our rules and policies, terms of service or the Website or Mobile Application EULA, or to protect our Website or Mobile Application, customers or others.

3.3.3. link your Non-Personally Identifiable Information, such as your IP address, with your Personally Identifiable Information when we feel that it is necessary to enforce compliance with our rules and policies, terms of service or the Website or Mobile Application EULA, or to protect our Website or Mobile Application, customers or others.3.4. Change in Corporate Control. In the event of a corporate change in control of any of us resulting from, for example, a sale to, or merger with, another entity, we reserve the right to transfer your Information to the new party in control.

3.4. Change in Corporate Control. In the event of a corporate change in control of any of us resulting from, for example, a sale to, or merger with, another entity, we reserve the right to transfer your Information to the new party in control.3.5. Information Retention. We may retain Information gathered through your use of the Website or Mobile Application for so long as is commercially reasonable for a legitimate business purpose.

3.5. Information Retention. We may retain Information gathered through your use of the Website or Mobile Application for so long as is commercially reasonable for a legitimate business purpose.

4. OPT IN AND OPT OUT. You may have the right to opt in to or opt out of certain of our uses and disclosures of your Personally Identifiable Information provided or obtained through the Website or Mobile Application. For example, you have the option to elect to, or not to, receive promotional messages from us by e-mail or receive messages of all types from us by Text Messaging (as defined in Section 4.2 below) by tapping on the “My Profile” tab in the Mobile Application and setting “Email,” or “SMS Text” to the “ON” or “OFF” setting, as applicable. You may also tell us that you wish to opt out of receiving promotional messages from us by e-mail or receiving messages of all types from us by Text Messaging or that you do not want us to share your Personally Identifiable Information with third parties for their marketing purposes by sending us your name, address, e-mail address, phone number and opt out request to: customerservice@palmcoenergy.com.

4.1. E-Mail. Another way to opt out of our promotional e-mails is by clicking on the opt out link within the e-mails you receive from us.

4.2. Text Messaging Service. We may seek to send text messages to you on your wireless device via short message service (“Text Messaging”). If you submit a wireless phone number (e.g., cell phone number) to us through the Website or Mobile Application or sign up for Text Messaging through the Mobile Application, which you may do by tapping the “My Profile” tab in the Mobile Application menu and then switching “SMS Text” to the “ON” setting, you agree to receive text messages from us at the wireless phone number (e.g., cell phone number) you provide unless and until you elect not to receive such messages by text messaging “STOP” to 33959 or by tapping the “My Profile” tab in the Mobile Application menu and then switching “SMS Text” to the “OFF” setting. Your opt out will be effective once we send you a Text Messaging confirmation of your opt out. If you opt out of Text Messaging, your wireless carrier’s standard rates may apply to any messages you receive (such as the Text Messaging opt out confirmation we send you). You represent that you are the owner or authorized user of the device you use to sign up for Text Messaging, and that you are authorized to approve the applicable charges. You must be 18 years of age or older and reside in the United States to use our Text Messaging. To opt into Text Messaging, you must provide all required Personally Identifiable Information, which may include, for example, your name, Text Messaging address (e.g., your cell phone number), and wireless carrier. We may also obtain the date, time and content of your messages in the course of your use of Text Messaging. We will use the information we obtain in connection with our Text Messaging in accordance with this Privacy Policy. If fees are charged to your wireless account invoice, we may provide information to your carrier about them. Your wireless carrier and other service providers may also collect data about your wireless device usage, and their practices are covered by their own policies. We may also access the content of your account with your wireless carrier for the purpose of identifying and resolving technical problems or service-related complaints. You may get help regarding our Text Messaging by texting “HELP” to 33959.

4.3. Opt Out Processing Time. Please understand that it may take us some time to process any opt out request and that even if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions and communications with us. Also, to stop receiving promotional messages from third parties who already have your contact information, please contact them directly.

5.  USE OF TRACKING TECHNOLOGIES.

5.1. As is the case with many websites and mobile applications, the Website and Mobile Application and our servers may automatically collect your IP address when you use the Website or Mobile Application, and we may associate it with your domain name or that of your Internet access provider. We may also capture certain “clickstream data” pertaining to your usage of the Website or Mobile Application. Clickstream data includes, for example, information about your device, computer, operating system, web browser and their settings, the pages or content you see or click on, and when and for how long you do so. In addition, we may deploy various tracking technologies in the Website or Mobile Application to collect additional information about your usage of the Website and Mobile Application. We do so to understand the usage of the Website or Mobile Application, to personalize the Website or Mobile Application for you and to improve our content and offerings. For Example:

5.1.1. Cookies: To enhance your experience on the Website or Mobile Application, we may place “cookies” on your computer or device. Cookies are small text files that we place in your computer or device to store your preferences. Cookies, by themselves, do not tell us your e-mail address or other Personally Identifiable Information unless you choose to provide this information to us. Once you choose to provide us with Personally Identifiable Information, this information may be linked to the data stored in the cookie. A cookie assigns a unique numerical identifier to your computer, web browser or device, and may enable us to recognize you as the same user who has used the Website or Mobile Application, and relate your use of the Website or Mobile Application to other information about you, such as your usage information and Personally Identifiable Information. Cookies may be also be used to enhance your experience on the Website or Mobile Application (for example, by storing your username so you can log in easily, keeping you logged in after you have provided your username and password, or tailoring content or product and service offerings to you) or to collect general usage and aggregated statistical information and detect and prevent fraud. If you wish to block cookies, go to http://www.allaboutcookies.org/ or check your web browser’s instructions to find out how. Most web browsers automatically accept cookies. You can set your web browser options so that you will not receive cookies and you can also delete existing cookies from your web browser. However, you may find that some parts of the Website or Mobile Application will not function properly if you have refused cookies or similar tracking technologies and you should be aware that disabling cookies or similar tracking technologies might prevent you from accessing certain Website or Mobile Application content or functionalities.

5.1.2. Local Shared Objects: Local shared objects, such as Flash cookies, also may be stored on your computer or device. Local shared objects operate a lot like cookies, but cannot be managed in the same way. Depending on how local shared objects are enabled on your computer or device, you may be able to manage them using software settings. For information on managing Flash cookies, for example, see http://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html.

5.1.3. HTML5: HTML5 (the language some websites and mobile applications are coded in) may be used to store information on your device about your Website or Mobile Application usage activities. This information can be retrieved by us to determine how the Website and Mobile Application are being used by our end users, how it can be improved, and to customize it for our end users.

5.1.4. Cache Cookies: Cache cookies, such as eTags, may be used to identify your computer or device as the same computer or device that used the Website or Mobile Application in the past.

5.1.5. Web Beacons: The Website or Mobile Application may also use small pieces of code called “web beacons” or “clear gifs” to collect anonymous and aggregate advertising metrics, such as counting page views, promotion views, or advertising responses. A web beacon is an electronic image called a single-pixel or clear GIF. Web beacons can recognize certain types of information, such as a user’s cookie number, time and date of a page view, and description of the page where the web beacon is placed. These web beacons may be used to deliver cookies that conform to our cookie policy above.

5.2. These tracking technologies may be deployed by us and/or by our service providers or partners on our behalf. These technologies enable us to assign a unique number to you, and relate your Website or Mobile Application usage information to other information about you, including your Personally Identifiable Information. We may match Information collected from you through different means or at different times, including both Personally Identifiable Information and Website or Mobile Application usage information, and use such Information along with offline and online information obtained from other sources (including third parties) such as demographic information and updated contact information (where that information has been lawfully disclosed to us) for the purposes of learning more about you so we can provide you with relevant content.

6.  YOUR ACCESS RIGHTS. You may review, update or modify certain of your Personally Identifiable Information that is stored in your user account on the Website or Mobile Application. We may ask you to verify your identity and to provide other details before we are able to provide you with any information, correct any inaccuracies, or delete any information. Your right to delete your Information is subject to our records retention policies.

7.  SECURITY OF YOUR INFORMATION.

7.1. We take reasonable precautions to help protect your Personally Identifiable Information from unauthorized access, use, or disclosure. Only employees, supervisors and vendors with specific authorization are allowed to access to databases with Personally Identifiable Information. When we transmit highly confidential information such as Personally Identifiable Information over the Internet, we protect it through the use of encryption. While we endeavor to protect the security and integrity of sensitive Personally Identifiable Information collected via the Website and Mobile Application, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that any information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers.

7.2. If you correspond with us by e-mail, text message, or form submissions through the Website or Mobile Application, you should be aware that your transmission might not be secure. A third party could view the information you send in transit by such means. We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission.

7.3. You are responsible for maintaining the strict confidentiality of your account username and password, and you shall be responsible for any activity that occurs using your account credentials, whether or not you authorized such activity. Please notify us of any unauthorized use of your password or account or any other breach of security.

7.4. If we believe that the security of your Personally Identifiable Information in our care may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we will endeavor to notify you as promptly as possible under the circumstances. If we have your e-mail address, we may notify you by e-mail in addition to, or in lieu of, by US Mail. You consent to our use of e-mail as a means of such notification. If you prefer for us to use US Mail to notify you in this situation, please e-mail us at customerservice@palmcoenergy.com.

8. CHILDREN’S ONLINE PRIVACY. The Website and Mobile Application, and the content contained therein, is not directed at children under the age of 13. We do not knowingly collect Personally Identifiable Information from children under the age of 13. If you are under the age of 13, please do not provide Personally Identifiable Information of any kind whatsoever. If a child does provide us with Personally Identifiable Information, a parent or guardian of that child should contact us by sending an e-mail to customerservice@palmcoenergy.com, calling us at 1-877-726-5862, or writing to:

PALMco Energy
8751 18th Avenue
Brooklyn, NY 11214

Upon notification of Personally Identifiable Information collected through the Website or Mobile Application of or from children under the age of 13, we will delete such Personally Identifiable Information from our records.

9.  CHANGES TO THIS PRIVACY POLICY. PALMco reserves the right to, in its sole discretion, modify, alter or otherwise update this Privacy Policy at any time. When PALMco does so, PALMco will let you know by making the updated Privacy Policy available on the Website and Mobile Application. Such updates will be applicable to you and your use of the Website or Mobile Application upon any further use by you of the Website or Mobile Application after the updated Privacy Policy has been made available on the Website or Mobile Application. Your use of the Website or Mobile Application following any such update constitutes your agreement to this Privacy Policy as updated. For this reason, we encourage you to review this Privacy Policy through the Website or Mobile Application whenever you use the Website or Mobile Application to stay informed of how PALMco is collecting, using and protecting your information. We may also, but will not be required to, tell you about updates to this Privacy Policy by additional means, such as by sending an e-mail to the e-mail address we have on file for you. The date on which this Privacy Policy was last updated is set forth at the end of this Privacy Policy.

10.  CONTACT INFORMATION. If you have any comments, questions or concerns regarding this Privacy Policy or our privacy practices, you may contact us by telephone, e-mail or postal mail.

PALMco Energy
8751 18th Avenue
Brooklyn, NY 11214
Toll Free: 1-877-726-5862
CustomerService@PalmcoEnergy.com