This policy statement is effective as of 8/13/2018.

AutoGrid Systems’ privacy policy covers our collection and use of information through our services to our Clients as defined below, as well as from our website: https://www.auto-grid.com and any direct email or other exchanges we may have with individuals. It also describes your choices regarding use, access and correction of your personal information. When you use our website or otherwise submit information to AutoGrid Systems as described below, you are consenting to the collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this privacy policy. When our Clients use our services, the use of any information we collect from these services shall be limited to the purpose of providing the service for which the Client has engaged us.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us at security@auto-grid.com .

Overview of our services
AutoGrid builds software applications that enable a smarter distributed energy world. The company’s suite of flexibility management applications enables utilities, electricity retailers, renewable energy project developers and energy service providers (collectively, “Clients”)) to deliver clean, affordable and reliable energy by managing networked distributed energy resources (DERs) in real time and at scale.

The information we receive
From our website, https://www.auto-grid.com , we may ask you to provide additional information that helps us enhance your site visit, assist you with technical support issues, or permit post-visit follow-up. For example, if you send us an information request email, we receive your email address, and any other information you provide, such as your name, telephone number, etc.

We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you such as IP address. This helps us to provide products and services that may be of interest to you, update, expand and analyze our records, and identify new prospective customers. Examples of the types of personal information that we may obtain from public sources or purchase from third parties and combine with information we already have about you include include your zip code or similar information so that we can provide to our customers an indication of the geographical concentration of connected devices.

We also receive information about you from our Clients. In providing our services to Clients and DER partners (for example, manufacturers of smart thermostats and storage batteries), we may receive data about their individual users from different sources. For example, we may receive data from our Clients’ smart meter readings, which may receive data about your electrical energy consumption usage. From a DER partner’s device(s) we may receive data about your electrical usage, heating and cooling information, usage patterns and current state of operation, i.e. on or off.

AutoGrid Systems collects this information under the direction of our Clients; we have no direct relationship with the individuals whose personal data we process. If you are a customer of one of our Clients, and would no longer like to be contacted by the Client that uses our service, please contact that Client directly.

We may also collect your contact details, record your questions or requests about our products or services, information about your background or your company, and how we followed-up, if you visit our booth at a trade show, you meet with our representatives at a networking event, or you participate in a survey or promotion. We assume that if you come to visit with us and provide us with your contact information, it is with the intent that we communicate with you about our products or services.

How the information is used
We use the information we receive to provide, usage forecasts, monitoring and control of DERs on our Client’s network. For example, we may optimize your storage battery operation to mitigate demand charges or provide time of use arbitrage, or call a demand response event, and reduce energy consumption of your water heater and air conditioner.

We may disclose the information we receive as follows:

• In certain situations, AutoGrid Systems may be required to disclose personal data in response to lawful requests by public authorities, including the need to meet national security or law enforcement requirements.
• If we believe that we have a legal obligation to do so, such as to comply with a subpoena or similar legal process.
• In situations where we believe it is necessary to protect ourselves, our customers or users or to prevent or stop activity we may consider to be or poses a risk of being illegal or legally actionable activity.
• In connection with a corporate merger, acquisition, sale of assets, bankruptcy, or other change in corporate status in which information is transferred to one or more third parties as one of our business assets and only if the recipient commits to a Privacy Policy that has terms substantially consistent with this Privacy Policy.
• You will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your personal information, and choices you may have regarding your personal information.
• We may also disclose your personal information to a third party with your prior consent.

What we don’t do with your information:

• We do not attempt to determine any additional personal information not provided directly to us.
• We do not sell your personal information to third parties.
• We do not provide your personal data to third parties who might create ads or advertising segments related to sensitive interests, such as, medical conditions, certain financial situations, sexual preferences and products, and use of firearms, drugs or alcohol.
• We do not deliver ads.
• We do not intentionally collect data from children under 13 years of age.

Interest Based Advertising
Interest based advertising is the collection of data from different sources and across different platforms in order to predict an individual’s preferences or interest and to deliver to that individual, or his/her computer, smart phone or tablet, advertising based on his/her assumed preference or interest inferred from the collection of data pertaining to that individual or others who have a similar profile or similar interests.

We work with a variety of third parties to attempt to understand the profiles of the individuals who are most likely to be interested in our services so that we can send them promotional emails, or serve our advertisements to them on the websites and mobile apps of other entities.

These third parties include: (a) advertising networks, which collect information about a person’s interests when that person views or interacts with one of their advertisements; (2) attribution partners, which measure the effectiveness of certain advertisements; and (3) business partners, which collect information when a person views or interacts with one of their advertisements.

In collaboration with these third parties, we collect information about our customers, prospects and other individuals over time and across different platforms when they use these platforms or interact with them to the extent permitted by applicable law. Individuals submit information directly on our website or on platforms run by third parties, or by interacting with us, our advertisements, or emails they receive from us or from third parties. We use special tools that are commonly used for this purpose, such as cookies, beacons, pixels, tags, mobile advertising IDs, flash cookies, and similar technologies to the extent permitted by applicable laws. We have access to databases of information collected by our business partners.

The information we or third party collect enables us to learn, what ads or content the person sees, on which ads or links the person clicks, and other actions that the person takes on our website, or in response to our emails, or when visiting or using third parties’ platforms.

We, or the third parties with which we work, use the information collected as described above to understand the various activities and behaviors of our customers, Site visitors and others. We, or these third parties, do this for many reasons, including: to recognize new or past visitors to our Site; to present more personalized content; to provide more useful and relevant ads – for example, if we know what ads you are shown we can try not to show you the same ones repeatedly; to identify visitors across devices, sales channels, third party websites and Sites, or to display or send personalized or targeted ads and other custom content that is more focused on a person’s perceived interest in products or services similar to those that we offer.

Our interest-based ads are served to you in emails or on third-party platforms. We serve these ads about our products or services or send commercial communications directly ourselves or through these third parties to the extent permitted by law.

Visitors may opt out of receiving interest based advertising by advertising networks that are delivered to them on our platform and other websites by visiting the following websites: http://go.auto-grid.com/u/DJX400e0QBn00N00320X0Ah . These features will opt a visitor out of many – but not all – of the interest-based advertising activities in which we or third parties engage.

Cookies

General
California law requires that operators of websites and online services disclose whether other third parties collect personally identifiable information about an individual’s online activities from their site or service. We allow third parties with which we have a separate agreement to use cookies and other technologies to collect information about your use of the AutoGrid website. These third parties include (1) business partners, which collect information when you view or interact with one of their advertisements on the website; and (2) advertising networks, which collect information about your interests when you view or interact with one of their advertisements.

The information gathered by these third parties is used to make predictions about your interests or preferences so that they can display advertisements or promotional material on our website and on other sites across the Internet tailored to your apparent interests.

The business partners and advertising networks that serve interest-based advertisements on our services have limited access to a small amount of information about your profile and your device, which is necessary to serve you advertisements that are tailored to your apparent interests. It is possible that they reuse this small amount of information on other sites or services.

We do not share with these third parties any information that would readily identify you (such as email address); however, these third parties will have access to information about your device (such as IP or MAC address). We do not have access to, or control over, the technologies that these third parties use to collect information about your interests, and the information practices of these third parties are not covered by this Privacy Policy. Other than as discussed in this document, we have no control over these third parties.

The Following Types of Cookies Are Used in the Site:
strictly necessary/essential cookies – These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies services you have asked for cannot be provided. These cookies do not collect information that identifies a visitor.

performance cookies – These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies do not collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.

functionality cookies – These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For instance, a website may be able to provide you with local weather reports or traffic news by storing in a cookie the region in which you are currently located. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect will be anonymized and they cannot track your browsing activity on other websites.

profiling cookies – These cookies are used to deliver adverts more relevant to you and your interests They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organization.

To Control Profiling Cookies
You may be able to block the use of cookies that are used to create a profile about you. For further information see:

Digital Advertising Alliance:
http://www.aboutads.info/choices/
http://www.aboutads.info
http://www.aboutads.info/consumers

Europe: http://youronlinechoices.eu

Canada: http://www.youradchoices.ca/choices/.

Network Advertising Initiative:
http://www.networkadvertising.org/choices/
http://www.networkadvertising.org
http://www.aboutads.info/consumers

Users of mobile device who do not want to receive interest-based advertising may opt-out in several ways.

Ad Choices for Mobile devices: http://www.aboutads.info/appchoices (it is necessary to first download the AppChoices app from http://www.aboutads.info/appchoices).

To end all targeting on a mobile device immediately, turn on “Limit Ad Tracking” in the device settings.

To limit Ad Tracking on an Apple device: https://support.apple.com/en-us/HT202074.

To limit Ad Tracking on an Android device: https://support.google.com/ads/answer/2662922

Disabling or blocking cookies
You can also delete cookies at any time using the settings of your browser. Please review the “Help” section of your browser.

CAUTION: If you block or delete technical and/or function cookies used by the website, the website may become impossible to browse, certain services or functions of the Website may become unavailable or other malfunctions may occur. In this case, you may have to modify or manually enter some information or preferences every time you visit the Website.

To delete or disable Flash Cookies, please visit:

http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html

Minors and Children’s Privacy
Protecting the privacy of young children is especially important. Our services are not directed to children under the age of 18, and we do not knowingly collect personal information from children under the age of 18 without obtaining parental consent. If you are under 18 years of age, then please do not use or access our website at any time or in any manner. If we learn that personal information has been collected on site from persons under 18 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 18 years of age has submitted personal information to AutoGrid, then you may alert us at security@auto-grid.com and request that we delete that child’s personal information from our systems.

Social Media Widgets
Our website includes Social Media Features, such as the Facebook Like button, and Widgets, such as the Share This button or interactive mini-programs that run on our website. These Features may collect your Internet protocol address, which page you are visiting on our website, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our website. Your interactions with these Features are governed by the privacy statement of the company providing it.

Security of Information
No company, including ours, can fully eliminate security risks associated with consumer information. We strive to protect your information. We follow generally accepted standards to protect the information we receive. However, no method of transmission, or method of electronic storage, is 100% secure. Technical mistakes are possible, and if such a mistake takes place, we will take commercially reasonable steps to correct it. We cannot guarantee absolute or warrant the security of any information you transmit to use or receive from us.

Service Providers
Sometimes we employ and contract with people and other entities that perform certain tasks on our behalf and who are under our control (our “Agents”). We may need to share your information with our Agents in order to make our services and site available to you. Unless we tell you differently, our Agents do not have any right to use your personally identifiable information or other information we share with them beyond what is necessary to assist us. AutoGrid Systems may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with our client.

Opting out of the services on the website
If you would like us to update, correct, delete, or deactivate any personally identifiable information that you have provided to us on our website, please send your request to us at security@auto-grid.com . Upon request we will provide you with information about whether we hold any of your personal information. We will respond to your request within a reasonable timeframe.

Data retention
We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Updating your information with our Client
AutoGrid Systems has no direct relationship with the end users whose personal data it processes on behalf of its Clients. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to the Client directly. If requested to remove data by our Clients, we will respond within a reasonable timeframe.

We will retain personal data we process on behalf of our Clients for as long as needed to provide services to them. AutoGrid Systems will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Links to Other Websites
Our website includes links to other sites whose privacy practices may differ from ours. If you submit personal information to any of those sites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any website you visit.

Updates
We reserve the right to modify or update our privacy policy from time to time. If we modify our policy, we will indicate when such terms are effective and will also update the “last updated” date. If we make a change to this policy that would result in a materially more permissive use of data that we collected before the effective date of the update, we will obtain prior affirmative consent from those affected users before implementing the change and we will send notification by email or by means of a notice on this website.

We encourage you to review this policy periodically to stay informed about how we collect, use, and disclose data.

Our Corporate Website; our Marketing Practices
Our corporate website at https://www.auto-grid.com is designed for our customers and their users. We do not collect personally identifiable information from users via our website unless users choose to provide it to us. Any information you submit to us will be used to send you the requested product or service information, or to respond to your questions or concerns. If you would like to discontinue receiving marketing emails, you may update your email preferences by using the “Unsubscribe” link found in emails we send to you or by contacting us at security@auto-grid.com .

Limitation of Liability
We exercise reasonable efforts to safeguard the security and confidentiality of your personal data; however, transmissions protected by industry standard technology and administered by humans cannot be guaranteed to be secure. We will not be liable for unauthorized disclosure of personal data that occurs through no fault of AutoGrid, including, but not limited to, errors in transmission, access to your account by anyone, your failure to comply with your security obligations, and the unauthorized acts of AutoGrid’s employees.

Rights of Individuals Located in California

Shine the Light
We will not share any personal information with third-parties for their direct marketing purposes to the extent prohibited by California law. If our practices change, we will do so in accordance with applicable laws and will notify you in advance.

Do Not Track
California law requires that operators of websites and online services disclose how they respond to a Do Not Track signal. Some browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference to the website or online service that a user visits, indicating that the user does not wish to be tracked. Because there is not yet a common understanding of how to interpret Do Not Track signals, we do not currently respond to Do Not Track signal. We continue to work with the online industry to define a common understanding of how to treat Do Not Track signals.

In the meantime, you may opt out of receiving interest-based advertising from advertising networks that are delivered on our platform and other websites by visiting the following websites. If you want to opt out of this online behavioral advertising, visit the following sites: http://www.aboutads.info/consumers and http://www.networkadvertising.org.

This will opt you out of many – but not all – of the interest-based advertising activities in which we or third parties engage. Choices you make may be browser and device specific. If you delete your cookies or use a different browser or a different computer or device, you may need to update your opt-out choices. Other third-party sites provide visitors with the ability to opt-out of receiving interest-based ads on their sites that you need to control through your settings on that Site. For example, to opt out of Google’s use of your online behavior for advertising purposes, visit Google’s Ad Settings page.

Use of the system from outside of the United States
If you are using our company’s commercial website, https://www.auto-grid.com, from outside of the United States, your information may be transferred to, stored in, or processed in the United States, where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country, but please be assured that we take steps to protect your privacy. By using our services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Policy.

AutoGrid Systems provides services in the EU where we primarily serve business clients, with use cases in which there is no individual consumer personal or device data shared with us. Our contracts with EU clients require us to adhere to EU Data Privacy and Austrian Data Privacy regulations. All data that is collected by our service in the EU (that is not from the AutoGrid System commercial website at https://www.auto-grid.com) is stored in the European Economic Zone and never transferred to other regions.

Disputes
If you have any concerns or claims with respect to our Privacy Policy, please contact us at security@auto-grid.com . We will investigate and attempt to resolve any complaints and disputes regarding our use and disclosure of personal data.

If the complaint or dispute cannot be resolved through our internal process, or AutoGrid does not adequately respond to your question, please contact the San Francisco office of the American Arbitration Association, which will serve as a liaison with AutoGrid to resolve your concerns.

If arbitration is necessary, it will be conducted by telephone and email, and if it must be done in person, it will be conducted in a location mutually agreeable to both parties. The arbitration will be conducted by one arbitrator member of the American Arbitration Association, and under the rules of commercial arbitration of the American Arbitration Association. All decisions of the arbitrator will be final and binding on both parties and enforceable in any court of competent jurisdiction.

Changes and Updates to this Policy
Please revisit this page periodically to stay aware of any changes to this Policy, which we will update from time to time. If we modify the Policy, we will make it available through our website, and indicate the date of the latest revision, and will comply with applicable law. Your continued use of the site or our services after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of the Policy.

How to Contact Us
Please contact us with any questions or comments about this Policy, your personal information, our use and disclosure practices, or your consent choices by email at security@auto-grid.com . If you have any concerns or complaints about this Policy or your personal information, you may contact our Data Protection Office by email at security@auto-grid.com .