Privacy Policy

Effective Date: 1/28/2025

 

Privacy Policy

Sun Light & Power (“SLP,” “we,” “our,” or “us”) respects your privacy and is committed to protecting your personal data. This online privacy policy discloses our information practices when you visit our website (sunlightandpower.com) (the “Website”), interact with our services, and/or engage with us. Please read this privacy policy carefully as it contains important information on who we are and our information practices, meaning how and why we collect, use, disclose, share, store, and retain your personal and non-personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint or request.

We collect, use, and are responsible for certain personal information about you. When we offer goods and services to individuals in the European Economic Area (EEA), we are subject to the EU General Data Protection Regulation (EU GDPR), which applies across the entire European Union. For California consumers, we are subject to the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). We are responsible as a “controller” of that personal information for the purposes of the GDPR. We are responsible for your personal information as a “business” under the CCPA/CPRA.

 

1. Key Terms. It would be helpful to start by explaining some key terms used in this policy:

 

Personal information	Any information relating to an identified or identifiable individual.
Special category personal information	Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, or trade union membership; genetic and biometric data; and data concerning health, sex life or sexual orientation.
Sensitive Personal Information	Personal information revealing a consumer's precise geolocation, contents of a consumer's mail, email and text messages where the business is not the intended recipient, genetic data or biometric information.
Biometric Information	An individual's physiological, biological, or behavioral characteristics, including information about an individual's deoxyribonucleic acid (DNA), that is used or is intended to be used singly or with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.

 

2. Information We Collect About and From You. We may collect and use the following personal and non-personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

                                                                                             

Categories of Personal Information	Specific Types of Personal Information Collected
Identifiers	Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers.
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual	Name, signature, physical characteristics or description, address, telephone number.
Commercial information	Details about your solar energy interests, quotes, and services you inquire about, records of personal property and real property, products or services purchased, obtained, or considered, referral submittal details, or other purchasing or consuming histories or tendencies
Internet or other electronic network activity information	Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
User-Submitted Content	Messages, requests, or other information you share through forms or customer service inquiries.

 

Categories of Non- Personal Information	Specific Types of Non-Personal Information Collected
Data that doesn’t identify an individual on its own.	Device Information: IP address, browser type, operating system, and device identifiers.  Usage Data: Pages visited, links clicked, and time spent on the Website.  Cookies and Tracking Technologies: Cookies and computer tracking technologies.

 

3. Children’s Privacy. Our Website and services are not intended for children under the age of 18. We do not knowingly collect personal data from children. If we learn that we have collected any personal or non-personal information from a child under 18, we will delete it promptly.
4. Third-Party Links. Our Website may contain links to third-party websites or services. We are not responsible for the privacy practices or content of these external websites. We encourage you to read their privacy policies before sharing any personal data
5. How Your Personal Information is Collected. We collect personal information from the following categories of sources:

• You, directly in person, by telephone, text, or email and/or via our Website and apps
• Third party with your consent
• Advertising networks
• Internet service providers
• Data analytics providers
• Government entities
• Operating systems and platforms
• Social networks
• Data brokers
• Publicly accessible sources (e.g., property records)
• Cookies on the Website
• Our IT and security systems, including, automated monitoring of our Website and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email, and instant messaging systems

6. How and Why We Use Your Personal Information. Under data protection laws, we can only use your personal information if we have a proper reason for doing so, for example:

• To comply with our legal and regulatory obligations
• For offering or providing services and/or products to you, or people referred by you, or to take steps at your request before entering into a contract
• For our legitimate interests or those of a third party –or–
• Where you have given consent

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for	Our reasons
To provide products and/or services to you and/or others	Process your requests, provide solar quotes, and facilitate transactions, for the performance of our contract with you or to take steps at your request before entering into a contract.
To improve the Website	Analyze usage trends and monitor Website performance.
To communicate with you	Send updates, respond to inquiries, and provide relevant marketing offers.
To prevent and detect fraud against you or SLP	For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you
Ensuring business policies are adhered to, e.g., policies covering security and internet use	For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can provide the best products and services.
Operational reasons, such as improving efficiency, training, and quality control	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best products and services at the best prices.
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information.
Statistical analysis to help us manage our business, e.g., in relation to our financial performance, customer base, product range or other efficiency measures	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best services at the best prices.
Preventing unauthorized access and modifications to systems	For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you, to comply with our legal and regulatory obligations.
Updating and enhancing customer records	To take steps at your request before entering into a contract, to comply with our legal and regulatory obligations, for our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products and services.
Statutory requirements	To comply with our legal and regulatory obligations.
Marketing our services and those of selected third parties to: Existing, former and potential future customers Third parties who have previously expressed an interest in our services Third parties with whom we have had no previous dealings	For our legitimate interests or those of a third party, i.e., to promote our business.
External audits and quality checks, e.g., for the audit of our accounts	For our legitimate interests or a those of a third party, i.e., to maintain our accreditations so we can demonstrate we operate at the highest standards, to comply with our legal and regulatory obligations.
With Your Consent	Use your information for any other purpose to which you expressly consent.

 

7. Who We Share Your Personal Information With. We routinely share personal information with:

• Our affiliates
• Service providers we use to help deliver our products and/or services to you, such as installers, financial partners, payment service providers, warehouses, and delivery companies
• Other third parties we use to help us run our business, such as marketing agencies or website hosts
• Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers
• Our insurers and brokers
• Our bank[s]
• In the event of a merger, acquisition, or sale of assets, your information may be transferred to the new owner

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with SLP’s auditors, e.g., in relation to the audit of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

8. Use of Computer Tracking Technologies. We use cookies and similar technologies to enhance your experience as described in this section.

• No Tracking of Personal Information. The Website is not set up to track, collect or distribute personal information not entered by visitors. Through Website access logs SLP does collect clickstream data and HTTP protocol elements, which generate certain kinds of non-identifying site usage data, such as the number of hits and visits to our sites. This information is used for internal purposes by technical support staff for research and development, user analysis and business decision making, all of which provides better services to the public. The statistics garnered, which contain no personal information and cannot be used to gather such information, may also be provided to third parties.
• Use of Cookies. SLP or its third-party vendors, collects non-identifiable and personal information through the use of various technologies, including "cookies". A cookie is an alphanumeric identifier that a website can transfer to customer's hard drive through customer's browser. The cookie is then stored on customer's computer as an anonymous tag that identifies the customer's computer, but not the customer. Cookies may be sent by SLP or its third-party vendors. Customer can set its browser to notify customer before a cookie is received, giving an opportunity to decide whether to accept the cookie. Customer may also set its browser to turn off cookies; however, the Website may not then work properly.
• Use of Web Beacon Technologies. SLP may also use Web beacon or other technologies to better tailor its Website to provide better customer service. If these technologies are in use, when a visitor accesses these pages of the Website, a non-identifiable notice of that visit is generated which may be processed by SLP or by its suppliers. Web beacons usually work in conjunction with cookies. If customer does not want cookie information to be associated with customer's visits to these pages, customer can set its browser to turn off cookies; however, Web beacon and other technologies will still detect visits to these pages, but the notices they generate cannot be associated with other non-identifiable cookie information and are disregarded.
• Collection of Non-Identifiable Information. SLP may collect non-identifiable information from user visits to the Website in order to provide better customer service. Examples of such collecting include: traffic analysis, such as tracking of the domains from which users visit, or tracking numbers of visitors; measuring visitor activity on the Website; Website and system administration; user analysis; and business decision making. Such information is sometimes known as "clickstream data." SLP or its contractors may use this data to analyze trends and statistics.
• Collection of Personal Information. SLP collects personal identifying information from customer during a transaction. SLP may extract some personally identifying information about that transaction in a non-identifiable format and combine it with other non-identifiable information, such as clickstream data. This information is used and analyzed only at an aggregate level (not at an individual level) to help SLP understand trends and patterns. This information is not reviewed at an individual level.

9. Personal Information We Shared. In the preceding 12 months, we have shared the following categories of personal information: 
   • Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers)
   • Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, their name, physical characteristics or description, address, telephone number
   • Characteristics of protected classifications under California or federal law
   • Commercial information (e.g., records of personal and/or real property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)
   • Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer's interaction with an internet website, application, or advertisement)
   • Geolocation data –and–
   • Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
10. Categories of Personal Information We Disclosed for a Business Purpose. In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose:

• Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers)
• Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, their name, physical characteristics or description, address, telephone number
• Characteristics of protected classifications under California or federal law
• Commercial information (e.g., records of personal and/or real property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)
• Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer's interaction with an internet website, application, or advertisement)
• Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes –and–
• Sensitive personal information

11. California Consumers: Your Rights Under the CCPA/CPRA. You have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You	You have the right to know, and request disclosure of: The categories of personal information we have collected about you, including sensitive personal information The categories of sources from which the personal information is collected The categories of third parties to whom we disclose personal information, if any –and– The specific pieces of personal information we have collected about you Please note that we are not required to: Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information –or– Provide the personal information to you more than twice in a 12-month period
Disclosure of Personal Information Shared or Disclosed for a Business Purpose	In connection with any personal information we may share or disclose to a third party for a business purpose, you have the right to know: The categories of personal information about you that we shared and the categories of third parties to whom the personal information was shared –and– The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose You have the right to opt-out of the sharing of your personal information for the purpose of targeted behavioral advertising. If you exercise your right to opt-out of the sharing of your personal information, we will refrain from sharing your personal information, unless you subsequently provide express authorization for the sharing of your personal information.
Right to Limit Use of Sensitive Personal Information	You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to: Perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services. To perform the following services: (1) Helping to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for these purposes; (2) Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer's current interaction with SLP, if the consumer's personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer's experience outside the current interaction with SLP; (3) Performing services on behalf of SLP, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of SLP; and (4) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by SLP, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by SLP  –and– As authorized by further regulations. You have a right to know if your sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes.
Right to Deletion	Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: Delete your personal information from our records –and– Direct third parties to whom the business has shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort. Please note that we may not delete your personal information if it is reasonably necessary to: Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us Help to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for those purposes Debug to identify and repair errors that impair existing intended functionality Exercise free speech, ensure the right of another consumer to exercise their right of free speech, or exercise another right provided for by law Comply with the California Electronic Communications Privacy Act 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 our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us Comply with an existing legal obligation –or– Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information
Right of Correction	If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.
Protection Against Retaliation	You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things: Deny goods or services to you Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties Provide a different level or quality of goods or services to you –or– Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information. We may also offer loyalty, rewards, premium features, discounts, or club card programs consistent with these rights or payments as compensation, for the collection of personal information, the sale of personal information, or the retention of personal information.

 

12. How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, you can call us at (510) 845-2997, or email us at info@sunlightandpower.com.

• Please note that you may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period.
• If you choose to contact us directly by email pr phone, you will need to provide us with:

• Enough information to identify you (e.g., your full name, address and customer or matter reference number)
• Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill) –and–
• A description of what right you want to exercise and the information to which your request relates

• We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person's behalf.
• Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

13. Data Retention and Security. We retain personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We implement appropriate technical and organizational measures to protect your data against unauthorized access, disclosure, alteration, and destruction. However, no method of transmission over the internet is 100% secure, and we cannot guarantee absolute security. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
14. How to File a GDPR Complaint. We hope that we can resolve any query or concern you raise about our use of your information. The GDPR also gives you right to lodge a complaint with a supervisory authority, in the European Union (or EEA) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
15. Changes to This Privacy Policy. We may update this Privacy Policy from time to time to reflect changes in legal requirements or our business practices. We will notify you of significant changes through reasonable means, such as email or announcements on our Website. The “Effective Date” at the top of this page indicates when the latest changes were made.
16. How to Contact Us. Please contact us by email, or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

Our contact details	Attn: Data Protection Manager Sun Light & Power
Address	1035 Folger Ave., Berkeley, CA 94710
Email address	info@sunlightandpower.com
Telephone number	(510) 845-2997

 

17. Do You Need Extra Help? If you would like this policy in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).
18. Governing Law and Agreement Terms. This Privacy Policy is governed by the laws of the State of California, without regard to conflict-of-law principles. Any disputes arising under this policy shall be resolved through binding arbitration in California, as described in our Terms of Use (“Terms”) for the Website, which are incorporated by reference herein.