Data Controller and Owner
Real Goods Solar, Inc. d/b/a RGS Energy
110 16th Street, Suite 300
Denver, CO 80202
Types of Data Collected
Among the types of Data that this Application collects, by itself or through third parties, are Cookie and Usage Data.
The Data may be freely provided by the User or collected automatically when using this Application.
Failure to provide certain Data may make it impossible for this Application to provide its services.
Users are responsible for any Data of third parties obtained, published or shared through this Application and confirm that they have the third party’s consent to provide the Data to the Owner.
MODE AND PLACE OF PROCESSING THE DATA
Methods of Processing
The Data Controller processes the Data of Users in a proper manner and shall take appropriate security measures to prevent accidental or unauthorized loss, access, use, disclosure, modification, or destruction of the Data. While we strive to protect User’s personal information, we cannot ensure the security of the information Users transmit to us, so we urge you to take every precaution to protect personal data while on the Internet, including but not limited to changing passwords often, using passwords containing a combination of letters and numbers, keeping passwords confidential, and making certain that to use a secure browser. Products and services are available from third parties that can help give Users privacy protection while navigating the Web.
Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary or desired, as “Data Processors” by us. The updated list of these parties may be requested from the RGS at any time.
Unfortunately, the transmission of information via the internet is not completely secure. Although we undertake measures to protect User’s personal information, we cannot guarantee the security of personal information transmitted to the Application. Any transmission of personal information is at the User’s own risk. We are not responsible for the efforts of others to circumvent any privacy settings or security measures contained on the Application. If for any reason whatsoever you feel your user ID and/or password have become compromised, please make contact immediately.
The Data is processed at the RGS’s operating offices and in any other places where the parties involved with the processing are located. For further information, please contact us.
The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request that we suspend or remove the data.
Use of the Collected Data
The Data concerning the User is collected to allow us to provide our services, as well as for the following purposes: analytics, access to third-party services’ accounts, interaction with external social networks and platforms, User database management, registration and authentication and remarketing and behavioral targeting. The Data used for each purpose is outlined in the specific sections of this document. In striving to serve Users, we sometimes shares User information with others so they may help us by providing services to us or by providing services on our behalf or jointly with us to Users. RGS does not sell personal information about Users to unrelated companies for their independent use.
Disclosure of Data
- To our affiliated companies;
- To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them; and
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of the RGS’s assets, in which personal information held by RGS about our site Users is among the assets transferred.
Detailed Information on the Processing of Data
Data is collected for the following purposes and using the following services:
- Access to third party services’ accounts
- Interaction with external social networks and platforms
These services allow interaction with social networks or other external platforms directly from the pages of this Application.
The interaction and information obtained by this Application are always subject to the User’s privacy settings for each social network. RGS does not control third party links or how they collect and use personal information. If you have any questions about how third parties may protect your personal information, you should contact those third parties directly.
If a service enabling interaction with social networks is installed it may still collect traffic data for the pages where the service is installed, even when Users do not use it.
Facebook “Like” Button and Social Widgets (Facebook, Inc.)
The Facebook “Like” button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.
Data collected: Cookie and Usage data.
- Registration and authentication
By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services.
In this case, this Application will be able to access some Data, stored by these third party services, for registration or identification purposes.
WordPress.com Single Sign On (Automatic Inc.)
WordPress.com Single Sign On is a registration and authentication service provided by Automatic Inc. and is connected to the WordPress.com network.
Twitter OAuth (Twitter, Inc.)
Twitter OAuth is a registration and authentication service provided by Twitter, Inc. and is connected to the Twitter social network.
These services allow this Application and its partners to inform, optimize and serve advertising based on past use of this Application by the User.
This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity.
Twitter Remarketing (Twitter, Inc.)
Twitter Remarketing is a Remarketing and Behavioral Targeting service provided by Twitter, Inc. that connects the activity of this Application with the Twitter advertising network.
Data collected: Cookie and Usage data.
Remarketing through Google Analytics for Display Advertising (Google Inc.)
Google Analytics for Display Advertising is a Remarketing and Behavioral Targeting service provided by Google Inc. that connects the tracking activity performed by Google Analytics and its Cookies with the Adwords advertising network and the Doubleclick Cookie.
Data collected: Cookie and Usage data.
- User Database Management
These services allow the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to this Application, as well as to track User activities through analytics features. This Data may also be matched with publicly available information about the User (such as social networks’ profiles) and used to build private profiles that the Owner can display and use for improving this Application.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Application. In addition, Owner may use a mailing address or phone number provided by Users for a variety of business-related reasons. Owner may send periodic mailings to Users or make telephone calls to inform those Users who have provided a mailing address or telephone number of new products, services or events. If you do not wish to receive such calls or mailings, you may request to be removed from the contact list by contacting Owner through the information at the beginning of this document.
Salesforce Sales Cloud (Salesforce.com, Inc.)
Salesforce Sales Cloud is a User database management service provided by Salesforce.com, Inc.
Pardot (Pardot LLC)
Pardot is a User database management service provided by Pardot LLC.
Further information about Data
- KeyVersion, Inc.
KeyVersion is a nurturing and remarketing service provided by KeyVersion, Inc. Their collection and usage of data collected on the RGS Energy website may be found at http://keyversion.com/privacy-policy.html
- Selling goods and services online
The Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
The Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by this Application depends on the payment system used.
Information about Cookies
ADDITIONAL INFORMATION ABOUT DATA COLLECTION AND PROCESSING
The User declares it is aware that the RGS may be required to reveal Data upon request of public authorities.
Additional Information about User’s Personal Data
System Logs and Maintenance
For operation and maintenance purposes, this Application and any third party services may collect files that record interaction with this Application (system logs) or other Data (such as IP Address) used for this purpose.
Information Not Contained in this Policy
More details concerning the collection or processing of Data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document.
The Rights of Users
Users have the right, at any time, to know whether their Data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller at the contact information set out above. Requests to change information the Data Controller believes would violate any law or legal requirement or cause the information to be incorrect may not be accommodated.
This Application does not support “Do Not Track” requests. To determine whether any of the third party services it uses honor the “Do Not Track” requests, please read their privacy policies.
- California Privacy Rights
- Other States Rights
California Civil Code Section § 1798.83 permits Users that are California residents to request certain information regarding the disclosure of personal information to third parties for direct marketing purposes. To make such a request, please see the contact information at the beginning of this document.
The site is intended to be used by adults only and not directed towards children under the age of eighteen. Accordingly, RGS does not intend to collect personal information from anyone known to be under the age of eighteen. If you believe that RGS has collected personal information from children under the age of eighteen, please notify RGS immediately so that steps may be taken to eliminate such information.
DEFINITIONS AND LEGAL REFERENCES
The hardware or software tool by which the Data of the User is collected.
Any information contained in Personal Data, Usage Data, or other data collected by use of the Application.
Data Controller (or Owner):
The natural person, legal person, public administration or any other body, association or organization with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Data and the means used, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
Data Processor (or Data Supervisor):
The legal or natural person to whom the Data refers.
Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including, but not limited to: first and last name; email address; a home, postal or other physical address or other contact information; title; birth date; gender; occupation; industry; personal interests; a personal identification number; and other information necessary or useful to provide a product or service the User requests.
Information collected automatically from this Application (or third party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
The individual using this Application, which must coincide with or be authorized by the Data Subject, to whom the Data refers.
Notice to European Users: This privacy statement has been prepared in fulfillment of the obligations under Art. 10 of EC Directive n. 95/46/EC, and under the provisions of Directive 2002/58/EC, as revised by Directive 2009/136/EC, on the subject of Cookies.
Latest update: July 22, 2015
QUESTIONNAIRES AND SURVEYS
On some occasions upon entering a page associated with the site, Users may be asked to complete either an online survey or questionnaire. These surveys and questionnaires will deal with the User’s opinions, attitudes, interests, and more generally about your activities online. It is important that the User answer these surveys and questionnaires accurately for they represent our only means to improve services offered through the site. Any personal information gathered from participation in questionnaires or surveys through the site will not be kept unless the User agrees to provide that information.
A WARNING ABOUT E-MAIL THAT WE SEND; A WARNING ABOUT “PHISHING”
Owner may send Users emails from time to time to provide them with energy-saving ideas and other useful information, updates regarding services, and special offers (whether available directly from RGS or from one or more of our business partners). Likewise, Owner may from time to time call the phone number associated with a User’s account.
However, Owner does not and will not at any time request any of the following information via email or through any telephone call initiated by Owner:
- User’s account user ID
- User’s account password
- User’s social security number
- User’s credit card and/or bank information
Likewise, Owner will never send you an unsolicited email containing a link to the log in page for the site. If you receive an email or telephone call requesting any of this information, it is likely that you have received an attempted theft of your identity commonly called “phishing.” Likewise, if you receive an email urging you to login to your account and provides you with a link to the login page, it is also likely that you have received a “phishing” attempt. In either case, you should bring the email to the attention of our security department by forwarding the email to: firstname.lastname@example.org.
If RGS sends you an email requesting that you login to your account, it is strongly recommended that you open your web browser and manually input the address for our website. Doing so will ensure that you do not open some third-party website disguised to look like our website.
For more information about “phishing,” you should visit the Federal Trade Commission’s website at www.ftc.gov.
TCPA COMPLIANCE (Telephone Consumer Protection Act)
By submitting your contact information, you are consenting to being contacted by RGS Energy at the phone number and email address provided. You may opt out of this by requesting to be added to our internal Do Not Call List at any time by sending an email to email@example.com or calling 888.56.SOLAR and requesting that no future contact be made without additional consent.
WARNING ABOUT SOCIAL MEDIA
In order to provide both current and potential customers with more options for contacting RGS, RGS has established Facebook and Twitter accounts. As these are public forums, Users should be aware that any personal information they choose to disclose through those platforms can be read, collected or used by others and that such disclosures are subject solely to the privacy policies and protections of those forums. RGS has no control over those forums and, thus, is not responsible for any personal information Users may choose to disclose through them. Users should also be aware that RGS will never disclose, or ask for Users to disclose, their non-public, personally identifying information (such as your Social Security number, bank information, etc.) through these public forums. RGS recommends that you not submit non-public, personally identifying information through these avenues. If there is a need for such information, RGS will provide you alternative communication methods.
PERSONAL INFORMATION COLLECTED FOR USERS INTERESTED IN LEASING SERVICES
For Users interested in a lease offering by RGS’s affiliate, RGS Financing, Inc., personal information is collected from Users or others on User’s behalf, on RGS’s credit evaluation request and other forms, including identifying information such as name, address, telephone number, date of birth, Social Security Number, bank routing information, and credit related information such as the User’s outstanding mortgages. RGS may also receive information about the User from consumer reporting agencies such as credit history, rating, and capacity.