Privacy Policy

Last Updated: May 13, 2020

Welcome to NovaSource Power Services’ (“NovaSource,” “we”, “us,” “our”) Privacy Policy (“Policy”).

NovaSource respects your privacy and is committed to protecting your Personal Information (which means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, to any individual or a household).  This Policy will inform you as to how we look after your Personal Information when you visit our website, how NovaSource collects, uses, and shares your Personal Information and other information, the choices that are available to you and your privacy rights, how the law protects you, and how you can contact us and exercise your legal rights.

This Policy is available at www.novasourcepower.com/privacy-policy, as well as offline.  We may change this Policy from time to time. Please review the “Last Updated” legend at the top of this page to see when this Policy was last revised and any effective date. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact NovaSource via the contact information provided in the Contact Us section below.

Note to California Residents:  California residents should review this Policy and the Additional Privacy Information For California Users section below, which contains information about California residents’ rights regarding Personal Information under the California Consumer Privacy Act of 2018 (“CCPA”).

Note to European Residents:  EU Citizens should review this Policy and the Additional Data Protection Rights for EU Citizens section below, which contains information about EU Citizen’s rights regarding Personal Information under the General Data Protection Regulation. 

This Policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively you can download a pdf version of the policy here.

  1. Information We Collect
  2. How Your Information is Collected
  3. How We Use Your Personal Information
  4. How We Share Your Information
  5. How We Protect Your Information
  6. Information Retention
  7. Children
  8. International Transfers
  9. Additional Data Protection Rights for EU Citizens
  10. Additional Privacy Information for California Residents
  11. Changes to this Privacy Policy
  12. Third-Party Links
  13. Contact Us

1. Information We Collect

NovaSource collects the information submitted by you through our website.  This includes Personal Information, such as your name, email address, and any other Personal Information you choose to share with us.  You can refuse to supply Personal Information, except that it may prevent us from being able to respond to you.

In the last twelve months, the Personal Information we have collected is limited to those categories above (full name, email address, and any other Personal Information you choose to directly share with us).

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your Personal Information but is not considered Personal Information as this data does not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Policy.

2. How Your Information is Collected

Information You Voluntarily Provide To Us
NovaSource collects information from you if you voluntary submitted it to us through direct interaction.  This means by submitting your information to us through our website or by other means of direct communication with us.  This includes submitting information and comments to us through the Talk to Usfeature of our website.


Information We Collect When You Use Our Services
We collect information through technology to enhance our ability to serve you. When you access and use our website, NovaSource and, in some cases, our third-party service providers collect information about how you interact with our website. We describe below methods we use to collect information through technology.


IP Address
When you visit our website, we collect information including your device identifier, browser characteristics, device characteristics, operating system, language preferences, and Internet Protocol (IP) address. An IP address is often associated with the portal you used to enter the Internet, like your Internet service provider (ISP), company, association, or university. While an IP address may reveal your ISP or geographic area, we cannot determine your identity solely based upon your IP address. We do not link your Personal Information to device identifier information, browser information, and IP addresses. Where, according to local law, IP addresses and the like are considered Personal Information, then we treat them as such.

Cookies
Cookies are small files that our website or our service provider transfers to your computer’s hard drive through your browser that enables our website or service provider’s systems to recognize your browser and capture and remember certain information. We use cookies to help us understand how users use our website. For example, cookies gather information about how long you spend on a web page so that we can understand what web pages are of most interest to users. If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off cookies by adjusting your browser settings. If you turn off your cookies, some of the features on our website may not function properly.

Information We Collect From Third Parties
We collect Personal Information from various third parties, including those listed below.  The collection, use, and disclosure of Personal Information received from third parties is governed by the privacy policies listed on the website where the information was submitted by the user.  Third parties may send their own cookies and pixel tags to you, and may collect information and use it in a way inconsistent with this Policy.  Please carefully review these third-party privacy policies to understand how your information may be collected, used and disclosed by these third parties.

Third Party Service Providers
We collect Personal Information from service providers including where we operate accounts on third-party platforms, such as call center and email platforms, and social media platforms.

Third Party Advertising Partners
We collect Personal Information received from third party advertising partners, including partners who host and manage various online advertisements


Google Analytics
We use third party cookies provided by Google Analytics to assist us in better understanding our website visitors.  These cookies collect IP address and usage data, such as the length of time a user spends on a page, the pages a user visits, and the websites a user visits before and after visiting our website. Based on this information, Google Analytics compiles data about website traffic and interactions, which we use to offer better user experiences and tools in the future.  For more information on Google Analytics, visit https://support.google.com/analytics


Third Party Cookies

We engage third-party service providers, including Google and Facebook, to serve ads to you about our products and services as you browse the Internet. These third-party providers may use their own cookies tags to track your online activities and purchases in order to deliver targeted advertising based on your interests. 


Do Not Track
Some browsers incorporate a Do Not Track (DNT) feature that signals to the websites that you visit that you do not want to have your online activity tracked.  At this time, our website does not respond to DNT signals.  Other third party websites may keep track of your browsing activities when they provide you with content, which enables them to customize what they present to you on their websites.

3. How We Use Your Personal Information

We will only use your Personal Information when the law allows us to. Most commonly, we will use your Personal Information in the following circumstances:

  • Where we need to respond to your comment or request for information
  • To provide you our products and services
  • To provide you with additional information on products and services that NovaSource offers
  • For internal business purposes such as complying with our internal policies
  • To protect our interests, including establishing, exercising and defending legal rights and claims
  • As necessary to comply with legal requirements
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests


Change of Purpose
We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please reach out to us at the information included in the Contact Us section below. 

If we need to use your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4. How We Share Your Information

NovaSource may share the information we collect, which is described above, in the following ways:

Business Partners, Vendors, and Affiliates
We may employ third party companies and individuals to perform certain business services on behalf of us and may disclose Personal Information to them as needed for them to perform such business services. These business services include, but are not limited, to any of the following: to facilitate the website; to process a payment, to provide the website or portions of the website on our behalf; to perform related services, including without limitation, maintenance services, database management, web analytics, marketing services, and improvement of the features or functionality; or to assist us in analyzing how the website is being used.  We require all third parties to respect the security of your Personal Information and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Information for their own purposes and only permit them to process your Personal Information for specified purposes and in accordance with our instructions.

Information You Instruct Us to Share. 
You may be presented with an option to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties. 

Business Transactions
In the event that we, or any portion of our assets, are acquired or we undergo another transaction in our business, your information may be transferred to the acquiring company or other entity surviving such transaction.

Law Enforcement
We may report to law enforcement agencies any activities that we reasonably believe to be unlawful, or that we reasonably believe may aid a law enforcement investigation into unlawful activity. In addition, we reserve the right to release your information to law enforcement agencies if we determine, in our sole judgment, that either you have violated our policies, or the release of your information may protect the rights, property, or safety of us or another person.

Legal Process
Subject to applicable law, we may disclose information about you (i) if we are required to do so by law, regulation or legal process, such as a subpoena; (ii) in response to requests by government entities, such as law enforcement authorities; (iii) when we believe disclosure is necessary or appropriate to prevent physical, financial or other harm, injury or loss; or (iv) in connection with an investigation of suspected or actual unlawful activity.

5. How We Protect Your Information

We employ appropriate data collection, storage and processing practices and security measures, including reasonable administrative, technical, and physical safeguards, to protect against unauthorized access, alteration, disclosure or destruction of your Personal Information and all other of your data stored on our website. Please be aware that, despite our best efforts, no security measures are perfect or impenetrable and, therefore, we cannot guarantee that your information will remain secure.

6. Information Retention

We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

7. Children

Our website is not intended for children and we do not knowingly collect data relating to children.  By using the website and submitting information to us, you represent and warrant that you are an adult.  If the parent or guardian of a child believes that the child has provided us with any Personal Information, the parent or guardian of that child should contact us via the information in the Contact Us section below and ask to have this information deleted from our files.

8. International Transfers

We may share your Personal Information within NovaSource across state and country lines. This may involve transferring your data into and out of the European Economic Area (“EEA”).  Whenever we transfer your Personal Information out of or into the EEA, we ensure a similar degree of protection is afforded to it by ensuring appropriate safeguards are implemented.Please contact us via the information included in the Contact Us section below if you want further information on the specific mechanism used by us when transferring your Personal Information into or out of the EEA.

9. Additional Data Protection Rights for EU Citizens

To make any of the following requests, please contact us via the information included in the Contact Us section below. 

Request access to your Personal Information
Commonly known as a “data subject access request”, this enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.

Request correction of the Personal Information that we hold about you
This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your Personal Information
This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where we may have processed your information data unlawfully or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your Personal Information
This enables you to object to processing of your Personal Information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your data which override your rights and freedoms.

Request restriction of processing of your Personal Information
This enables you to ask us to suspend the processing of your Personal Information in the following scenarios:

  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your Personal Information but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your Personal Information to you or to a third party.
We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw Consent
This enables you to withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Complaints
If you are in the European Economic Area or in the United Kingdom, you have the right to make a complaint at any time to your national supervisory authority for data protection/privacy issues.  We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority, so please contact us in the first instance at the contact information in the Contact Us section below. 

10. Additional Privacy Information for California Residents

The California Consumer Privacy Act of 2018 (“CCPA”) provides consumers (California residents) with specific rights regarding their “Personal Information”. This section describes your CCPA rights and how to exercise those rights. This section applies only to California residents and to “Personal Information” as that term is defined under the CCPA.

Please make sure you also consult our general privacy policy above for complete information.

Access to Specific Information and Data Portability Rights:
You have the right to request that NovaSource disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will 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 or selling that Personal Information.
  • The categories of third parties with whom we share that Personal Information.
  • The specific pieces of Personal Information we collected about you (also called a data portability request).
  • If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
    • sales, identifying the Personal Information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Rights
You have the right to request that NovaSource delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) 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 products 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 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 information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
    • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
    • Comply with a legal obligation.
    • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

  • You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
    • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
    • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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 consumer request does not require you to create an account with us.
  • We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. 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 consumer request unless it is excessive, repetitive, 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
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, 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.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to info@novasourcepower.com.

11. Changes to this Privacy Policy

Please check back periodically as this Policy may change from time to time. NovaSource has the discretion to update this Policy at any time without prior notice to you to reflect changes in our information practices or relevant laws. We will notify you of any material changes by posting the new Policy on the website. We will indicate at the top of the Policy when it was last updated. Information gathered by NovaSource is and will be subject to the Policy in effect at the time the information is gathered.  If you do not agree with any changes to the Policy, you should not access or use the website. You acknowledge and agree that it is your responsibility to review this Policy periodically and become aware of modifications.

12. Third-Party Links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the applicable privacy policy of every website you visit.

13. Contact Us

If you have any questions about this Policy, the practices of this website, or your dealings with this website, please contact us at:

Name: NovaSource Power Services

Address: 8900 Amberglen Blvd, Suite 325, Austin, TX 78729

Phone: 1 (510) 260-8206

Email: info@novasourcepower.com

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