Privacy Policy

Last updated February 18, 2021

Palmetto, Inc. (“we” or “us”) wants you to be familiar with how we collect, use, and disclose information. This Privacy Policy describes our practices in connection with information that we collect through the Palmetto Platform, as well as through emails that we send to you (together, the “Platform”).

If you are a California resident, please see the section entitled “Additional Information Regarding California,” below, for more details about our privacy practices and your rights.

If you are a California resident whose Personal Information we collect in the context of your role as our employee, job applicant, contractor, owner, director, or officer, including information about your emergency contacts and dependents, please see the section entitled “California Notice for Employees, Job Applicants, Contractors, Owners, Directors, and Officers,” below, for information about our privacy practices

Personal Information

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. We collect Personal Information through the Platform and from third-party sources, including:

- Name - Mailing Address - Telephone Number - Email Address - IP Address (we may also derive your approximate location from your IP address) - Payment Card Information - Utility billing information - Energy usage and production information

Collection of Personal Information

We and our service providers collect Personal Information through the Platform, for example, when you register an account, purchase a subscription, or contact us.

Use of Personal Information

We and our service providers use Personal Information for the following purposes:

Providing the functionality of the Platform to you.

- To provide the Platform’s functionality to you, such as arranging access to your account and providing you with related customer service. - To respond to your inquiries and fulfill your requests. - To complete your transactions, verify your information, collect payment from you, and provide you with related customer service. - To send administrative information to you, such as changes to our terms, conditions, and policies.

Providing you with marketing materials.

- To send you marketing related emails, phone calls, and text messages, with information about our products and services and other news about our company.

Anonymizing and/or aggregating Personal Information.

- We may anonymize and/or aggregate Personal Information so that it will no longer be considered Personal Information. We may use and disclose such anonymized and/or aggregated information for any purpose.

Accomplishing our business purposes.

- For data analysis, for example, to understand how the Platform is used and improve its efficiency; - For audits, to verify that our internal processes function as intended, and to address legal, regulatory, or contractual requirements; - For fraud and security monitoring purposes, including to detect and prevent cyberattacks or attempts to commit identity theft; - For monitoring use of the Platform for compliance with our End User License Agreement and other agreements applicable to the Platform; - For improving, repairing, maintaining, or modifying the Platform; and - For developing new products and services.

Disclosure of Personal Information

We disclose Personal Information to our third-party service providers, to facilitate services they provide to us. These can include providers of services such as Platform hosting, data analysis, payment processing, information technology, and related infrastructure provision, customer service, email delivery, and auditing.

Other Uses and Disclosures

We also use and disclose your Personal Information as necessary or appropriate:

To comply with applicable law and regulations.

To cooperate with law enforcement or public and government authorities.

- To respond to a request or order or to provide information we believe is necessary or appropriate.

For other legal reasons.

- To enforce our End User License Agreement and other agreements applicable to the Platform; and - To protect our rights, privacy, safety, or property, and/or that of you or others.

In connection with a sale or business transaction.

- We may disclose or transfer your Personal Information to a third party in connection with any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

Other Information

“Other Information” is information that does not reveal your specific identity or directly relate to an identifiable individual. We and our service providers collect Other Information in a variety of ways, including:

Through your browser or device.

- Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, and browser type and version. We use this information to ensure that the Platform functions properly.

Through the use of cookies.

- Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect such information as browser type, time spent on the Platform, pages visited, and other traffic data. We use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about use of the Platform in order to continually improve its design and functionality, understand how it is used, and assist us with resolving questions about it. If you do not want information collected through cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting cookies from a particular website. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If you do not accept cookies, you may experience some inconvenience in your use of the Platform. - We do not currently respond to browser do-not-track signals.

Through pixel tags and other similar technologies.

- Pixel tags. We may use pixel tags (also known as web beacons and clear GIFs) to, among other things, track the actions of Platform users (including email recipients), measure the success of our marketing campaigns, and compile statistics about Platform use. - Analytics. We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Platform and report on activities and trends. This service may also collect information regarding the use of other online services. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/‌partners and exercise its opt-out by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Through Adobe Flash technology (including Flash Local Shared Objects (“Flash LSOs”)) and other similar technologies.

- We may use Flash LSOs and other technologies to, among other things, collect and store information about your use of the Platform. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also go to the Global Storage Settings Panel and follow the instructions. Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications.

Physical Location.

- We may collect the physical location of your device by, for example, using satellite, cell phone tower, or WiFi signals. We use your device’s physical location to provide you with personalized location-based services and content. You may be permitted to allow or deny such use, but, if you do, we may not be able to provide you with the applicable personalized services and content. - Through energy meters or other mechanical devices installed at the physical location.

Use and Discolsures of Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Privacy Policy. If we combine Other Information with Personal Information, we will treat the combined information as Personal Information as long as it is combined.

Mobile Terms and Conditions

Palmetto Alerts

Receive account updates, technology updates, and promotional messages from Palmetto. Opt-in by texting POWER to 76527. Message frequency varies. Message and data rates may apply. By opting in to this service, you consent to receive mobile text alerts using an automatic telephone dialing system. Consent to receive marketing text messages is not required as a condition of purchasing any goods or services. By signing up, you are confirming you are over the age of 13.

STOP Information

Text STOP to 76527 to stop receiving Palmetto Alerts messages from Palmetto (you will receive a confirmation text).

HELP Information

For additional information, text HELP to 76527 or contact 1-855-339-1831.

Supported Carriers

AT&T, Sprint, T-Mobile®, Verizon Wireless, Boost, Cricket, MetroPCS, U.S. Cellular, Virgin Mobile, Google Voice, ACS Wireless, Advantage Cellular (DTC Wireless), Appalachian Wireless, Atlantic Tele-Network International (ATN), Bandwidth, Bluegrass Cellular, Buffalo Wireless, CableVision, Carolina West Wireless, Cellcom, Copper Valley, C-Spire Wireless (formerly Cellsouth), Cellular One of East Central Illinois, Chariton Valley Cellular, Cross (dba Sprocket), Duet IP, Element Mobile, EpicTouch, GCI Communications, Golden State, Hawkeye (Chat Mobility), Hawkeye (NW Missouri Cellular), i Wireless (IOWA Wireless), Illinois Valley Cellular, Immix (Keystone Wireless / PC Management), Inland Cellular, Mobi PCS (Coral Wireless LLC), Mosaic, MTA Communications, MTPCS / Cellular One (Cellone Nation), Nex-Tech Wireless, Panhandle Telecommunications, Peoples Wireless, Pine Belt Wireless, Pine Cellular, Pioneer, Plateau, Revol Wireless, RINA, SI Wireless/Mobile Nation, SouthernLinc, SRT Wireless, Thumb Cellular, Union Wireless, United, Viaero Wireless, West Central Wireless, Leaco, Nemont/Sagebrush. T-Mobile is not liable for delayed or undelivered messages.

Security

We seek to use reasonable organizational, technical, and administrative measures designed to protect Personal Information within our organization. Unfortunately, no information transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.

Choices and Acceas

Your choices regarding our use of your Personal Information for marketing purposes.

If you prefer that we no longer send you email marketing, please opt out by using the unsubscribe instructions contained in each such email. If you prefer that we no longer send you marketing text messages, please opt out by replying “STOP” to any such message. If you prefer that we no longer place telemarketing calls to you, please inform the sales representative who calls you or email [email protected] with such request.

How you can request to access, correct, update, or delete your Personal Information

If you would like to request to correct, update, or delete Personal Information, please contact us in accordance with the “Contact Us” section below. We will respond to your request consistent with applicable law. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting deletion.

Third Party Services

This Privacy Policy does not address, and we are not responsible for, the privacy, information security, or other practices of any third parties, including any third party that advertises or places a link on the Platform. The inclusion of advertising or a link on the Platform does not imply endorsement of the linked site or service by us.

Jurisdiction and Cross-Border Transfer

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and, by using the Platform, you understand that your information may be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.

Sensitive Information

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, or criminal background) on or through the Platform or otherwise to us.

Updates To This Privacy Policy

The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Platform.

Contact Us

If you have any questions about this Privacy Policy, please contact us at [email protected] or:

Palmetto Solar, LLC Attn: General Counsel 505 King Street, Suite #200 Charleston, SC 29405

ADDITIONAL INFORMATION REGARDING CALIFORNIA

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), this Privacy Policy provides California residents with a description of our online and offline practices regarding the collection, use, and disclosure of their Personal Information. Under the CCPA, “Personal Information” is information that identifies, relates to, describes, or could reasonably be associated or linked with a particular California resident or household.

Collection of Personal Information

We collect the following categories of Personal Information, as listed in the CCPA:

A. “Identifiers.” Identifiers, such as name, mailing address, telephone number, email address, and IP address;

B. “Customer Records Information.” Personal information as defined in the California customer records law, such as payment card information;

C. “Protected Classifications” under California or federal law—specifically, primary language;

D. “Transaction Information.” Commercial information, such as transaction information and purchase history;

E. “Online Use Information.” Internet or network activity information, such as browsing history, search history, and interactions with our online properties;

F. “Geolocation Data.” Geolocation data such as device location and approximate location derived from IP address;

G. “Inferences.” Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

Sources of Personal Information

We collect this Personal Information from you, as well as from other companies.

Our Use of Personal Information

We use this Personal Information as set forth in the section entitled “Use of Personal Information,” above.

Disclosure of Personal Information

We share Personal Information with the following categories of third parties:

- “Service Providers.” We share with our trusted third-party service providers, to facilitate services they provide to us, such as Platform hosting, data analytics, payment processing, information technology and related infrastructure provision, customer service, email delivery, and auditing.

- “Legal Authorities.” We share with public and government authorities, including regulators and law enforcement, to respond to requests, as well as to protect and defend legal rights.

- “Other Parties in Litigation.” We share information in the context of litigation discovery and in response to subpoenas and court orders.

- “Financiers.” We share information with financial institutions in connection with your loan application.

In the preceding 12 months, we disclosed for our operational business purposes the following categories of Personal Information to the following categories of third parties:

1. Identifiers - Service Providers; Financiers

2. Customer Records Information - Service Providers; Financiers

3. Protected Classifications (primary language) - Service Providers; Financiers

4. Transaction Information - Service Providers; Financiers

5. Online Use Information - Service Providers; Financiers

6. Geolocation Data - Service Providers; Financiers

7. Inferences - Service Providers; Financiers

We do not “sell” and have not “sold” Personal Information for purposes of the CCPA in the last 12 months. We do not sell the Personal Information of minors under 16 years of age.

Your CCPA Rights

Requests to Know and Delete

If you are a California resident, you may make the following requests:

1. “Request to Know”

You may request that we disclose to you the following information covering the 12 months preceding your request:

- The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;

- The specific pieces of Personal Information we collected about you; The business or commercial purpose for collecting Personal Information about you; and

- The categories of Personal Information about you that we shared or disclosed, and, for each, the categories of third parties with whom we shared or to whom we disclosed such Personal Information.

2. “Request to Delete”

You may request that we delete Personal Information we collected from you.

To make a Request to Know or a Request to Delete, please contact us at [email protected] or 1-855-339-1831. We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you, such as confirmation of email account ownership, in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information. If you make a Request to Delete, we may ask you to confirm your request before we delete your Personal Information.

If you are the authorized agent of a consumer, making a Request to Know or a Request to Delete on behalf of the consumer, we will ask you for:

1. Proof of your registration with the California Secretary of State to conduct business in California.

2. Proof that the consumer has authorized you to make a Request to Know or a Request to Delete on the consumer’s behalf. This must be a permission signed by the consumer. “Signed” means that the permission has either been physically signed or provided electronically in accordance with the Uniform Electronic Transactions Act, Civil Code 1633.7 et seq.

If an authorized agent has not provided us with a power of attorney from the consumer pursuant to Probate Code sections 4000-4465, we may also:

1. Require the consumer to provide you with a written permission signed by the consumer to make the request on the consumer’s behalf.

2. Verify the identity of the consumer as we would if the consumer were making the request personally.

3. Obtain verification from the consumer that they provided the authorized agent permission to make the request.

Right to Non-Discrimination

You have the right to be free from unlawful discriminatory treatment for exercising your rights under the CCPA.

CALIFORNIA NOTICE FOR EMPLOYEES, JOB APPLICANTS, CONTRACTORS, OWNERS, DIRECTORS, AND OFFICERS

Consistent with the CCPA, we provide the following details regarding the Personal Information that we collect and use about California residents in the context of their current, former, or potential role as our employees, job applicants, contractors, owners, directors, or officers, including such individuals’ emergency contacts, dependents, and beneficiaries.

Categories of Personal Information

We collect the following categories of Personal Information:

1. Identifiers, such as name, contact information, online identifiers, IP address, Social Security numbers, and other government-issued ID numbers;

2. Personal information, as defined in the California customer records law, such as name, contact information, education information, employment history, financial information, and medical and medical insurance information;

3. Characteristics of protected classifications under California or federal law, such as sex, age, race, religion, national origin, disability, medical conditions and information, citizenship, immigration status, request for leave, and marital status;

4. Biometric information, such as fingerprints and voiceprints;

5. Internet or network activity information, such as browsing history and interactions with our websites and systems;

6. Geolocation data, such as device location;

7. Information collected in background checks;

8. Audio, electronic, visual, and similar information, such as video recordings; and

9. Audio, electronic, visual, and similar information, such as photographs or audio or video recordings created in connection with our business activities;

10. Professional or employment-related information, such as work history, prior employer, information relating to references, details of qualifications, skills and experience, human resources data, and data necessary for benefits and related administration services;

11. Education information subject to the federal Family Educational Rights and Privacy Act; and

12. Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences, behavior, or characteristics.

Use of Personal Information

We use this Personal Information for the purposes of operating, managing, and maintaining our business, managing our workforce, and accomplishing our business purposes and objectives, including, for example, to:

- Manage workforce activities and personnel generally, including for recruitment, performance management, career development, payments administration, employee training, leaves and promotions;

- Manage wages and other awards such as stock options, stock grants, and bonuses, and provide healthcare, pensions, savings plans, and other benefits;

- Maintain and secure our facilities, equipment, systems, and infrastructure;

- Undertake quality and safety assurance measures, protect the health and safety of our workforce and others, and conduct risk and security control and monitoring;

- Conduct research, analytics, and data analysis to assist in planning succession and to ensure business continuity, as well as to design employee retention programs and diversity initiatives;

- Perform identity verification, accounting, audit, and other internal functions, such as internal investigations;

- Operate and manage IT and communications systems and facilities, allocate company assets and human resources, and undertake strategic planning and project management; and

- Comply with law, legal process, internal policies, and other requirements, such as income tax deductions, record-keeping and reporting obligations, and to exercise and defend legal claims.

Contact Us

Please contact [email protected] if you have any questions regarding this notice.