Indra Energy Privacy Policy

Updated October 19, 2023

1. Introduction

This Indra Energy Privacy Policy (“Privacy Policy” or “Policy”) describes how Palmco Energy DE, LLC, Palmco Power DE, LLC, Palmco Energy DC, LLC, Palmco Power DC, LLC, Palmco Energy IL, LLC, Palmco Power IL, LLC, Palmco Energy IN, LLC, Palmco Energy MD, LLC, Palmco Power MD, LLC, Palmco Energy MA, LLC, Palmco Power MA, LLC, Palmco Energy MI, LLC, Palmco Energy NJ, LLC, Palmco Power NJ, LLC, Palmco Energy PA, LLC, Palmco Power PA, LLC, Palmco Energy VA, LLC, and Palmco Power VA, LLC, affiliated and related entities, d/b/a Indra Energy (“Indra Energy,” “us,” “we,” or “our”), collect, use, share, secure and eventually delete the Personal Information that we collect from You through our Website, our interactions with You over the phone or offline, and other sources.

Please note that this Policy does not apply to any affiliate or related entity of Indra Energy that maintains and publishes its own privacy policy, but does apply to all websites and services that refer to this Policy. We have endeavored to make this Policy clear and easy to navigate. However, if You have any questions about the Policy You can contact us as described in the “Contact Information” section, below.

By continuing to visit and use this Website, You are agreeing to the terms of this Policy. If You do not agree, then please exit the Website and close Your browser.

2. Definitions

Please note the following definitions as You read through the Policy:

• A. “Customer” means a natural person that has purchased a residential service plan with us.
• B. “Commercial Customer” means a business that has purchased a commercial service plan with us.
• C. “Personal Data” means Personal Information.
• D. “Personal Information” means any information relating to an identified or identifiable individual that is collected from our Customers and Users via the Website. Personal Information may include a Customer’s or a User’s: full name, physical address, email address, IP address, or other identifier such as from a cookie.
• Personal Information does not include any aggregate or anonymized data that may have been created from Personal Information but can no longer be used to identify, relate to or could reasonably be linked to a Customer or a User.
• E. “Sensitive Personal Information” means any information collected from our Customers and Users that reveals a racial or ethnic origin, political opinion, religious belief, philosophical belief or trade union membership. It also may include a natural person’s genetic and biometric data, financial information, and data concerning their health, sex life or sexual orientation.
• F. “User” means a natural person that visits and interacts with the Website.
• G. “Website” means https://www.indraenergy.com/.
• H. “You” or “Your” means a Customer or User.

3. Information That We Collect Through the Website

We collect certain Personal Information from You in order to operate our Website effectively and provide You with the best experiences when You visit and use them. Specifically, we collect Your Personal Information from:

• A. Information Provided by You
• When You register for a My Energy Perks account online, we will collect certain Personal Information about You such as Your name, address, e-mail address, date of birth or age range, telephone number, and general geographic location (such as Your zip code or city and state). If You purchase our services, we would also need to collect any information that You use to make a purchase, such as Your credit card details (cardholder name, card number, expiration date, etc.).
• If You are looking for more information with regards to our commercial services, and You fill out a request for a consultation on our website, we will collect Your name, business email address, business phone number, the physical address of the business, and business name (which is likely also Your employer’s name). If You are interested in learning more about our commercial partnerships, and You fill out a contact form for that purpose, we will collect Your name, business email address, business phone number, the physical address of the business, and business name (which is likely also Your employer’s name).
• If You are a job applicant applying for a job with us, we will collect Your name, email address and information related to Your work history. We may also need to collect Your phone number and home address as well. In the event that You are offered the position, we will need to collect additional Personal Information and Sensitive Personal Information from You in order to offer You the job and get You started in the same.
• B. Information Collected Automatically
• We also may use various technologies to collect information from Your computer or device and about Your activities when visiting or using our Website.
  • a. Information Collected Automatically: We may automatically collect information from You when You visit our Website. This information may include Your IP address, location data, Your browser type and language, access times, the content of any un-deleted cookies that Your browser previously accepted from us, referring or exit website address, internet service provider, date/time stamp, operating system, locale and language preferences, and system configuration information.
  • b. Google Analytics: We use Google Analytics to collect information about Your use of our Website as well. To disable Google Analytics, please download the browser add-on for the deactivation of Google Analytics provided by Google here at https://tools.google.com/dlpage/gaoptout?hl=en, To learn more about privacy and Google Analytics, please consult the Google Analytics overview provided by Google: https://www.google.com/intl/en/policies/privacy/.
  • We may also collect information from You automatically through any site or web application that we may develop and run on a third party social network. This could also include any site or application that we specifically design for use on a cell phone or other mobile device, such as a mobile-enabled site (i.e., WAP site) or mobile application (e.g., iPad/iPhone app).
  • c. Information Collected Directly from Your Google User Account: If You are visiting our Website, and You are signed into Your Google Account while browsing or have otherwise allowed general access to Your Google account information, then we will collect that information automatically as well but subject to the following restrictions:
    • 1. The Website will only be able to use such access to read, write, modify, or control Gmail message bodies (including attachments), metadata, headers, and settings to provide a web email client that allows Users to compose, send, read, and process emails and will not transfer this Gmail data to others unless doing so is necessary to provide and improve these features, comply with applicable law, or as part of a merger, acquisition, or sale of assets.
    • 2. The Website will not use this Gmail data for serving advertisements.
    • 3. The Website will not allow humans to read this data unless: (i) we have Your affirmative consent to do so for specific messages, (ii) doing so is necessary for security purposes such as investigating abuse, (iii) we need to do so to comply with applicable law, or (iv) we need to do so for our Website’s internal operations and even then only when the data has been aggregated and anonymized.
    • 4. The Website’s use and transfer to any other website or application of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements, which can be found here: https://developers.google.com/terms/api-services-user-data-policy
      
  • d. Cookies: When You visit our Website, we may assign Your device one or more cookies to facilitate access to our site and to personalize Your online experience. Through the use of a cookie, we also may automatically collect information about Your online activity on our site, such as the web pages You visit, the links You click, and the searches You conduct on our site. Most browsers automatically accept cookies, but You can usually modify Your browser setting to decline cookies.
  • A cookie is a small text file that is stored on a User’s computer for record keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when You close Your browser and is used to make it easier for You to navigate our Website. A persistent cookie remains on Your hard drive for an extended period of time.
  • We use cookies to personalize content and ads, to provide social media features and to analyze our traffic. We also share information about Your use of our Website with our social media, advertising and analytics partners, who may combine it with other information that You’ve provided to them or that they’ve collected from Your use of their services.
  • e. Other Technologies: We may use standard Internet technology, such as web beacons and other similar technologies, to track Your use of our website. We also may include web beacons in promotional e-mail messages or newsletters to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customize the services we offer, deliver targeted advertisements, and to measure the overall effectiveness of our online advertising, content, programming, or other activities. Web beacons (also known as clear gifs, pixel tags or web bugs) are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web Users or to access cookies. Unlike cookies, which are stored on Your device, web beacons are embedded invisibly on the web pages (or in emails) and are about the size of the period at the end of this sentence. Web beacons may be used to deliver or communicate with cookies, to count visitors to certain pages, and to understand usage patterns. We also may receive an anonymous identification number if You come to the Website from an online advertisement displayed on a third-party website.

4. Information We Collect Via Phone, Email, Regular Mail, and Fax

• A.Text Messaging Program: If You have signed up to receive text messages from us, we may collect information from You through one of our inbound text messaging programs. In addition to the message itself, we may also collect Your geolocation information as well and use that information to send You personalized marketing messages. We do not share Your mobile telephone number with any third parties to use for their own promotional/marketing purposes.
• B.Call Center and Customer Service: If You contact us over the phone in order to place a service order, speak to our Customer Service department or send a fax or postal mail to our customer service department, we will collect certain Personal Information from You, such as Your name, home address, e-mail address, financial information, and phone number. We may also need to use Your Personal Information to place Your order, or further contact You to respond to Your inquiry or request.

5. Information Collected Via Social MediaIf You have consented on a third-party social media site to sharing Your Personal Information with other third-parties, then we may collect Your Personal Information that is part of Your profile or that You post publicly. Examples may include Your basic account information (e.g., name, email address, profile picture, gender, birthday, current city, User ID, list of friends, etc.) and any other additional information or activities that You permit the third party social network to share with application developers or that You post publicly on an Indra social networking page. For example, we may receive Your social network information (or parts of it) when You download or interact with an Indra application on a social networking site or use a third party social networking feature that is integrated within our Website. This is Personal Information that is shared with us, and You should consult the third-party social media site that You use for more information on how they collect Your Personal Information and how to opt out of such collection and otherwise exercise Your rights.

6. Information Collected From Third PartiesOccasionally, we may obtain information about You from third-parties, such as a data aggregator or vendor to provide us with additional information about our existing customers (this is known as “data appending”), which may include information from Your profile or Your postings on a third-party social network. We may also receive information from third-party co-sponsors who we may partner with occasionally to run special promotions or giveaways, and we may use that information to contact You directly. We may also receive information about customers from other companies that we may acquire. We may also receive information from other methods that are not inconsistent with this Policy.

7. Customer Surveys and Feedback Forms

We may ask You to voluntarily share with us comments on and aspects of Your experience in using our services and Website via customer surveys online and feedback forms that we may e-mail or mail to You. We may also collect comments and suggestions about our services and Website, testimonials, or other feedback You send us about what You may have liked (or disliked) about Your experience in using our services. We may engage the services of a third-party to conduct these surveys on our behalf, both offline and online, and they will then share your responses with us so that, as described further below, we can evaluate our services and provide new ones.

Please note that we welcome and appreciate Your feedback and suggestions. But if You send the same to us, we reserve the right to use the same freely without any restrictions, credit to You, or compensation to You. Additionally, we are under no obligation to keep any such suggestions confidential.

8. Why We Collect Your Information

We collect Your Personal Information for various reasons, which are described below:

• A. To Service Our Website: We use information collected to ensure that our Website is working as intended and for analytics purposes, to understand how the Website is operating and learn how it can be improved. We also use this information as needed for auditing purposes as well.
• B. To Provide Our Services to You: We collect information from You to set up and deliver the services You have requested.
• C. To Maintain Your Account: We may use information collected to maintain Your rewards account(s) with us, including administering any services associated with such accounts.
• D. For Our Marketing Purposes: If You have signed up to receive our alerts, or have otherwise signed up to receive our direct communications, we may use this information to send You marketing communications, such as email communications, mobile messages (including text and/or push notifications), and postal mailings. These communications may inform You about new products and services. On occasion, these communications may also contain information or offers about third party products and services. In some instances (such as for mobile messages), we may use technical information or precise geo-location information obtained from Your mobile device to send You messages directly to Your mobile device. You can opt out of receiving these communications at any time by clicking the “opt out” link at the bottom of these emails or by clicking here.
• E. To Evaluate and Improve our Customer Service: We may use this information to ensure we are providing the highest level of customer service, and to identify any potential gaps or potential improvements to the same. Customer service may be provided through various forms of communication, such as email correspondence and call center support.
• F. To Evaluate, Improve, and Customize Our Services: We may use information collected to improve our services, tailor them to Your needs, and come up with new products and services.
• G. To Administer Contest and Promotions: We may use information collected to administer a contest, sweepstakes, giveaway, competition, or other similar marketing campaign or promotion. To comply with sweepstakes laws, we may publish or share limited information about promotion winners (such as name and city of residence).
• H. In Order to Respond from Requests from You. If You have requested further information or in any other way requested that we contact You, we will use Your Personal Information to respond to such a request.
• I. To Provide a Personalized and Convenient Website Experience for You: We may use information collected to personalize Your experience and save You time when You visit our Website. For example, we might remember Your login ID or Username so You can quickly login the next time You visit our site.
• J. For Our Other General Purposes. We may use information collected other general business purposes, such as to maintain the day-to-day operation and security of the Website, and to conduct internal marketing and demographic studies.
• K. For Our Legal Purposes. We also collect information in order to comply with certain legal rules and regulations that we are subject to.

9. How Long do We Store and Maintain Your Personal Information

We only store and maintain Your Personal Information for as long as is necessary to fulfill the purpose for which it was collected. For example, if You sign up to receive to receive job alerts, we will store and maintain Your Personal Information to continue to send You these materials until You opt out of receiving such communications. With regards to Your Personal Information collected for our analytics purposes and used to help maintain and improve the Website, we only store and maintain that information until it is aggregated and used to create a new anonymous data set that no longer contains Your Personal Information, and then delete the underlying Personal Information once that new data set has been created. If You are one of our valued Customers and have created an account with us, we store Your Information as long as Your account remains active, and then delete it when You delete the account, with the exception of any information that we are legally required to maintain longer. If You are a Customer and You do not have an account, we only store Your information as long as needed to support Your relationship with us. When we no longer have a legal need, or You close or delete Your account with us, or otherwise ask us to delete Your account, we will do so securely in accordance with our document retention policy.

10. Sale of Your Personal Information

Indra Energy does not generally sell any Personal Information that it has collected via the Website to any third parties. However, we do share Your information with both our affiliates and our non-affiliates so that they can market their products and services to You. Additionally, our use of analytics providers for the Website may be considered a sale and thus, to the extent that such activity constitutes a sale, this would be a situation in which we would sell Your Personal Information.

11. Who We Share Your Personal Information With

Generally, we share Your Personal Information as necessary to provide the services You request, including sharing information with certain third parties, such as service providers. We also may share Your Personal Information when required to by law; to protect Your rights and safety, and with Your consent.

Specifically, we may share Your Personal Information with third parties, including:A. Authorized service providers: We may share Your Personal Information with our authorized service providers that perform certain services on our behalf. These services may include relationship management software; website hosting; evaluators, contractors and auditors; email marketing providers; customer service providers; providers that perform business and operations analysis for us; and providers that support and maintain the Website, including providing analytics services for us.B. Our Advertising Partners: We may also allow third parties through an advertising network to target custom content and ads to You on the Website. The information provided to these service providers is limited to only that which we deem appropriate for these service providers to carry out their functions and enable us to market to You.C. For a Legal Reason: We may have to share Your Personal Information in response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.D. To Prevent Fraud or Illegal Conduct: We may have to share Your Personal Information in situations where we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property, or safety of our company, our consumers, our employees, or others; or to enforce our Terms of Service or other agreements or policies.E. With Our Affiliates: We may share Your Personal Information with our affiliates. For additional information regarding our affiliates, please visit the Website.F. For Corporate Reasons: We may also share Your Personal Information as part of a sale, merger, or change in control or ownership of Indra Energy, or in the unlikely event of bankruptcy, or in preparation for any of these events. If such an event should happen, the new entity would have the right to continue to use Your information, but only in the manner that is set out in this Policy, unless You otherwise agree.G. With Your Consent: To other third parties that You provide consent to share Your information with or that You have requested that we share Your information with.

12. Children’s Personal Information

Indra Energy does not knowingly market to or collect information from children under 16. The Website and our services are not geared for or marketed to children under the age of 16.

13. Third-Party Tracking on Our Website

Third-parties may be using cookies or other technologies to collect Your Personal Information as You navigate through the internet including from our Website. As described above, You may decline these third-party cookies by changing Your browser settings.

14. Links to Other Websites

Indra Energy may provide links to other companies, including social media companies, on the Website. If You choose to link to websites not controlled by us, Indra Energy is not responsible for the privacy or security of these sites, including the accuracy, completeness, reliability or suitability of their information. If You are asked to provide information on one of these websites, You are strongly urged to carefully study their privacy policies before sharing Your information.

15. How do we Secure and Protect Your Personal Information

Indra Energy maintains a comprehensive Information Security Program that employs commercially available physical and IT securitization tools, including but not limited to:

• A. Commercially available and sufficient firewalls;
• B. Segmented Data Storage;
• C. Encryption;
• D. Multi-factor authentication; and
• E. Policies providing for least privileged access to data across our organization.

Unfortunately, however, there is no way to completely eliminate the risk of a data security incident. If we do suffer one that affects any of Your Personal Information, we will report the same to You as per applicable data breach notification laws.

We also ask that You do Your part to keep Your account information safe and secure, by asking that You create a sufficiently complex password for Your account and not share it with third parties, and also, that You enable Multi-factor authentication for Your account. If You have any questions about the cybersecurity for the Website, You can send an email to techs@indraenergy.com.

16. Changes to this Policy

Indra Energy reserves the right to, in its sole discretion, modify, alter or otherwise update this Policy at any time. When Indra Energy does so, Indra Energy will let You know by updating the effective date noted at the top of this Privacy Policy. We encourage You to review our Policy whenever You use the Website.

17. Contact Information

If You have any comments, questions or concerns regarding this Policy or our privacy practices, You may contact us by telephone, e-mail or postal mail:

Address: 1515 Market Street, Suite 1200, Philadelphia, PA 19102
Toll Free: (888) 504-6372
Email: CustomerCare@IndraEnergy.com