Effective Date: 1st June 2021
Solar Gen Group, Inc. and its subsidiaries and affiliated entities (collectively “Solar Gen Group,” “Solar Gen Group,” “we”, “us” or “our”) are primarily engaged in the business of digital marketing for the solar installation industry that assists solar installation clients and other third parties market and sells solar installation products and services to Consumers through our programs for online Consumer referrals, client marketing products and services, email marketing, postal advertising and online advertising. The primary component of our business is the collection of Personal Information voluntarily provided by Consumers in order to refer the Consumer to Third Party Clients and other Third Parties offering products and services related to the solar installation field.
“Consumer” means a natural person.
“Personal Information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
“Third Party” means a person or entity not owned, operated or controlled by Solar Gen Group or any person or entity owned, operated or controlled by Solar Gen Group.
We collect Voluntarily-Provided Personal Information and Automatically-Collected Personal Information through the means described below.
Voluntarily-Provided Personal Information
“Voluntarily-Provided Personal Information” means Personal Information collected from a Consumer as a result of the Consumer providing that information voluntarily to Solar Gen Group or to a Third Party that sells or otherwise transfers the Personal Information to Solar Gen Group. Solar Gen Group collects Voluntarily-Provided Personal Information only when you make it available through your use of a feature or service offered by Solar Gen Group or a Third Party that requires the entry of Voluntarily-Provided Personal Information in order to provide the product or service you have requested. The types of Personal Information that a Consumer provides will depend on the nature of the submission for the products or services the Consumer is requesting, but typically will include the following:
“Consumer Requests” means the submission of a specific request online from a Consumer that (i) is initiated by the Consumer; (ii) contains Voluntarily-Provided Personal Information furnished by the Consumer; and (iii) expresses the Consumer’s interest in (1) a new solar installation quote or other information regarding Solar installation pay-per-lead generation; or (2) other products and services offered by Third Parties. We collect Voluntarily-Provided Personal Information in Consumer Requests submitted by Consumers directly from Solar Gen Group Sites or that were submitted by Consumers through Third Parties and that was acquired by us from the Third Parties in order to provide the Consumer’s Voluntarily-Provided Personal Information to a solar installation client other Third Party that can contact the Consumer directly and provide the Consumer with the product, service or information that the Consumer has requested or in which the Consumer may have an interest or to send the Consumer advertising, marketing or content. Consumers may come to Solar Gen Group Sites to submit Consumer Requests directly by visiting a Solar Gen Group Site or may indirectly submit Consumer Requests to us by clicking on advertisements or links to Solar Gen Group Sites that Solar Gen Group places or have placed on Third-Party sites, social media platforms or emails sent by Solar Gen Group or Third Parties.
We may conduct surveys of Consumers who have submitted Consumer Requests for marketing purposes and to better target our content to our audience or for the benefit of Third Parties with whom we do business. We also conduct follow-up surveys to confirm that a Consumer was contacted by the Third Parties to which the Consumer was referred for a product or service and to assess the Consumer’s experience with the Third Party.
Automatically-Collected Personal Information
“Automatically-Collected Personal Information” is Personal Information collected automatically through the use of Data Technologies without any action or entry of Personal Information by a Consumer when the Consumer visits or uses Solar Gen Group Sites or Third Party Sites. Automatically-Collected Information does not identify a Consumer personally and cannot be linked back to a Consumer unless the Consumer decides at some point to identify the Consumer by submitting Voluntarily-Provided Information.
Solar Gen Group collects the following Automatically-Collected Personal Information from a Consumer’s desktop computer, laptop or handheld or mobile device when the Consumer visits a Solar Gen Group Site, even if the Consumer does not submit Voluntarily-Provided Personal Information:
Internet or Other Electronic Network Activity, including:
Automatically-Collected Personal Information generates “online behavioural information,” which is the collection of data online from a particular computer or device regarding Web viewing behaviours over time, and across non-affiliated Web sites, for the purpose of using such data to predict visitor preferences or interests. Online behavioural information includes browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement. Online behavioural information may be used to generate “interest-based advertising," also called "online behavioural advertising,” which is advertising that is customized and targeted based on predictions generated over time from a Consumer’s visits across different websites, devices and mobile applications.
“Data Technologies” are technologies, such as cookies, local shared objects, pixels and web beacons, used to collect information about your actions and your visit to Solar Gen Group Sites or Third Party Sites, and includes all current and similar future technologies, including anonymous advertising identifications used on mobile devices and otherwise in a manner similar to cookies. One or more Data Technologies may be used on the Solar Gen Group Sites and other websites and mobile applications (that may not be the Solar Gen Group Sites) by Solar Gen Group or Third Parties. Data Technologies may be used to collect information about web pages you visited and visit and to transmit information to you or about you and connect information about you from different sources, websites, devices, and mobile applications. Solar Gen Group places or "sets" Solar Gen Group cookies on a Consumer’s computer or device when the Consumer visits Solar Gen Group Sites. We may also set cookies on a Consumer’s computer or device on behalf of Third Parties authorized by Solar Gen Group or may enable certain Third Parties to set their own cookies on the Consumer’s computer or device.
Solar Gen Group uses Third-Party tracking services for which Solar Gen Group sets cookies on your computer or enables the Third Party tracking services to set cookies on your computer or device when you visit Solar Gen Group Sites. These cookies track visits, page views and clickstream behaviour. Third-Party tracking services report this data to Solar Gen Group in aggregated form so Solar Gen Group can better understand our users and improve the Solar Gen Group Sites. Solar Gen Group shares such anonymous, aggregated information obtained from these cookies with our advertisers and other Third Parties.
Anytime you visit Solar Gen Group Sites, we collect the Internet Protocol (“IP”) address to help diagnose problems with our servers, administer the Solar Gen Group Sites and track site usage statistics. A Consumer’s IP address may vary each time the Consumer visits, or it may be the same, depending on how the Consumer accesses the Internet. We also collect information on whether the Consumer reached a Solar Gen Group Site by clicking on a link or advertisement on a Third Party site, which helps us to maximize our Internet exposure and to understand the interests of our users. We also collect information on the Consumer’s ISP or mobile carrier and the type of handheld or mobile device the Consumer used. All of this information is collected and used only in the aggregate; that is, it is entered into our database, where we can use it to generate overall reports on our visitors, but not reports about individual visitors.
Solar Gen Group uses Google Analytics to collect information through Data Technologies. This data is collected on an anonymized basis and is aggregated, but may include or be associated with other non-Personal Information or with Voluntarily-Provided Personal Information. Our primary goal in collecting user information is to enhance a Consumer’s experience on Solar Gen Group Sites. Google Analytics is a web analytics tool provided by Google, Inc. ("Google") that helps website owners understand how visitors engage with their website. We can view a variety of reports about how visitors interact with Solar Gen Group Sites so we can improve the Solar Gen Group Sites. Google uses first-party cookies and IP addresses, and it reports website trends without identifying individual visitors. For more information related to Google Analytics, click here.
“Advertising Networks” are Third Parties that serve interest-based advertising to Consumers and generate statistics and metrics related to the delivery of interest-based advertising. Solar Gen Group engages with Advertising Networks that may use information collected through a variety of Data Technologies to provide customization, auditing, research and reporting for us, our affiliates and other advertisers. This data collection takes place both on the Solar Gen Group Sites and on Third-Party’s websites and mobile applications. This process allows Solar Gen Group and Third-Parties to deliver interest-based advertising, enhance marketing programs and help track the effectiveness of such efforts. Advertising Networks also may use this information for determining or predicting the characteristics and preferences of their respective advertising audiences and measuring the effectiveness of their advertising.
Mobile-specific information we may collect
Solar Gen Group collects information from a Consumer’s mobile devices such as hardware IDs and device type, the request type, your carrier, the Consumer’s carrier user ID, and the content of the Consumer’s request, which does not by itself identify the Consumer, though it may be unique or consist of or contain information that the Consumer may consider personal.
Trackable Telephone Numbers
We publish uniquely generated, trackable phone numbers for many of the clients that list offerings on the Solar Gen Group Sites or in advertisements posted on Solar Gen Group Sites. If a Consumer dials one of these phone numbers, Solar Gen Group or a service provider operating on Solar Gen Group's behalf may record the date, time and length of the Consumer’s call and the phone number from which the call originated.
“Geolocation Information” is physical location information that is sufficiently precise to allow us to locate a computer or device, including data such as the Consumer’s computer or mobile device’s physical location and may include GPS-based, WiFi-based or cell-based location information. When a Consumer downloads or uses the Solar Gen Group Sites, we may collect Geolocation Information. We may use Geolocation Information and provide it to Third Parties to provide the Consumer with content and services that are relevant to a particular location, such as advertising, search results, clients in the area, and directions and to customize marketing to the Consumer for what is available in the Consumer’s area or close proximity. This Geolocation Information may reveal a Consumer’s actual location, such as GPS data, or it may not, such as when the Consumer submits a partial address to look at a map of the area.
Combined or Appended Personal Information and Personal Information from Other Sources
We may combine Voluntarily-Provided Information or Automatically-Collected Information for a Consumer with other information that is voluntarily provided by Consumers or automatically collected by us or Third Parties. The combined information may include information about the Consumer’s use of the Solar Gen Group Sites; use of other websites, devices and mobile applications; interactions or transactions with clients; interests and preferences; and other information about the Consumer or the Consumer’s household.
When we refer a Consumer to a client we may obtain Personal Information that we did not originally provide to the solar installation company in a Consumer Request from sales matching information that we acquire from the solar installation company or other Third Parties. Sales matching information may include the Consumer’s name, postal address, phone number, and email address; the purchase price; and the purchase date.
III. How We Use and Share Personal Information We Collect
Internal Use by Solar Gen Group
Personal Information collected by Solar Gen Group is used internally by Solar Gen Group to improve the content or layout of the Solar Gen Group Sites; improve user experience on Solar Gen Group Sites; provide services requested by users of the Solar Gen Group Sites; respond to questions, requests or complaints from Consumers; request feedback from Consumers; develop new products and services; evaluate the effectiveness of the Solar Gen Group Sites; and to contact Consumers for marketing purposes, including through email and SMS/text marketing.
When a Consumer provides the Consumer’s email address as Voluntarily-Provided Information, we automatically include the Consumer’s name and email address and other Voluntarily-Provided Information in our marketing database to receive email communications from us that contain marketing, advertisements and content. We may collect information regarding the effectiveness of our email and other communications with the Consumer.
Third Parties To Which We Sell or Otherwise Share, Transfer or Disclose Your Personal Information
We may sell, disclose, or transfer Personal Information to Third Parties under the following circumstances:
We may aggregate Personal Information from all of our users and provide that information in the aggregate to the solar installation company, advertisers and other Third Parties for marketing and promotional purposes. However, if we do so, that information will be anonymized so as not to be personally identifiable.
“Service Providers” are Third Parties that have contracted with Solar Gen Group to provide services to or on behalf of Solar Gen Group that may involve access to or processing of Personal Information collected by Solar Gen Group. We may allow Third-Party Service Providers (such as market research firms, marketing services providers, advertising agencies and information processors) access to your Personal Information to perform services on our behalf.
Solar Gen Group will cooperate with legal authorities, and may in some circumstances be required to disclose Personal Information in response to requests from law enforcement or other governmental agencies, or in response to a subpoena or other legal process. We can also share information about you if we believe we must in order to (i) prevent a violation of the law; (ii) protect or defend our interests and the legal rights or property of Solar Gen Group and our affiliates; (iii) protect the rights, interests, safety and security of users of the Solar Gen Group Sites or members of the public; (iv) protect against fraud or for risk management purposes; or (v) comply with prudent legal practice as we may determine, and with applicable law or legal process. We may also share Personal Information in the course of legal proceedings if we are legally required to do so, if we reasonably believe that doing so may mitigate our liability, or if doing so will assist us in enforcing our legal rights.
Business Transfers and Other Transactions
Information about our users and the Solar Gen Group Sites is a business asset of Solar Gen Group. As we continue to develop our business, we might sell or buy websites, subsidiaries or business units. In such transactions, Personal Information generally is one of the transferred business assets. Also, in the event that Solar Gen Group or substantially all of its assets are acquired, Personal Information will of course be one of the transferred assets. In addition, Personal Information will be disclosed as part of any creation of a separate business to provide a Solar Gen Group Site or to provide other services or fulfil products; debt financing, sale or pledge of Solar Gen Group assets, or insolvency, bankruptcy or receivership. We will make reasonable efforts to ensure that the acquirer of our users' Personal Information respects the provisions of this Policy, although this may not be possible in certain legal settings (such as bankruptcy).
You may limit and control the Personal Information collected by us in a number of ways.
Voluntarily-Provided Personal Information
You are not required to provide any Voluntarily-Provided Personal Information to visit or use the Solar Gen Group Sites. You may elect to not provide Voluntarily-Provided Personal Information for any purpose. However, in doing so, you may not be able to use all features of the Solar Gen Group Sites. For example, if you do not provide the Voluntarily-Provided Information required to submit a Consumer Request, you will not be able to submit Consumer Requests, and Solar Gen Group and clients and other third party service and product providers will not be able to contact you to provide you with the products, services or information in which you may be interested. You may also choose not to participate in surveys.
Opting Out of Email Marketing
In addition, we provide you with the opportunity to indicate your preferences as to what types of offerings of products or services you wish to receive from third parties or, subject to the exceptions below, to opt-out of disclosures to those third parties altogether. You may update your preferences at any time by contacting us at firstname.lastname@example.org. Those third parties who receive your Personal Information prior to your opt-out will remain able to send you communications, subject to their privacy policies and practices. To opt out from receiving third party emails, you must contact those third parties directly.
Even if a consumer decides not to receive offers or other product or service information, Solar Gen Group, other product and services providers, fulfilment third parties and other referral services with which Solar Gen Group has relationships, may use a phone number, mailing address or email address that the Consumer has provided to contact the Consumer regarding a Consumer Request that the Consumer submitted. Additionally, phone numbers and email addresses may be used to conduct customer surveys regarding individual experiences with Solar Gen Group, solar installation companies, or other product and services providers. Phone numbers and email addresses are made available only to Solar Gen Group, its affiliates, other referral services, fulfilment third parties and other referral services who receive a Consumer Request.
If a Consumer request to opt-out of receiving emails from us and then subsequently submits a Consumer Request (either directly or submitted through a Third-Party and are referred to us), we will reinstate the relationship with us and we will the Consumer’s Personal Information as set forth herein unless the Consumer subsequently requests to opt-out. Each time a Consumer submits a Consumer Request, this process will restart.
Automatically-Collected Personal Information
Opting Out of Data Technologies
Consumers have a number of choices regarding certain Data Technologies.
Most web browsers automatically accept cookies, but a Consumer can usually modify the Consumer’s browser’s setting to decline cookies if the Consumer prefers. Consumers have the ability to accept or decline cookies by modifying the Consumer’s browser settings, and our websites are viewable even if the Consumer disables the cookie function on the Consumer’s browser. However, if a Consumer disables cookies, note that certain features may not function properly or at all as a result, and some advanced and customized features or offerings will not be available to the Consumer, including personalization features.
If a Consumer prefers not to accept cookies, the Consumer should consult the documentation for the Consumer’s browser or device for more information. Most browsers will explain how to view and disable cookies under the help portion of the toolbar or notify the Consumer when the Consumer receives a new cookie. Use of third party cookies is subject to the privacy policies and opt-out procedures of these third parties and not Solar Gen Group's policy and procedures. Please click here www.networkadvertising.org in order to learn more about the data and information collection and use practices of some of the third parties for which we set cookies on Solar Gen Group Websites or for which we enable to set their own cookies. Please click here http://www.networkadvertising.org/managing/opt_out.asp in order to learn more about the "opt-out" procedures of some of these third parties. At times, not all of the third parties for which we set cookies on Solar Gen Group Websites or for which we enable to set their own cookies are included in the preceding link to opt-out from these cookies. Should you wish to opt out of these cookies, a Consumer will need to access the third party’s website to determine their opt-out procedure.
A Consumer may also render some web beacons unusable by rejecting their associated cookies and disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on's settings or opting out at www.evidon.com or the website of the technology provider.
A Consumer may refuse to accept a cookie from us on mobile devices by adjusting the use of advertising identifiers through the settings on the Consumer’s computer or device. A Consumer’s mobile device may also have settings that allow the Consumer to prevent sharing Geolocation Information with us. Consumers should consult their mobile device’s settings or help documentation for more information about exercising these options.
Consumers can opt-out of the delivery of interest-based advertising to the Consumer by multiple companies by visiting www.aboutads.info/choices, www.networkadvertising.org/managing/opt_out.asp and www.evidon.com. Please note that even if a consumer opts out, the Consumer will continue to receive advertisements, but the advertisements will not be tailored to the Consumer’s specific interests.
Solar Gen Group uses Google Analytics, which helps Solar Gen Group better understand its audience and target communications and advertisements based on demographic or interest-based information. Consumers may learn more about opting out of certain Google advertising initiatives and install the Google Analytics Opt-out Browser Add-on here. Please note that Consumers may still receive advertising even after opting out, but that advertising may not be tailored to the Consumer or the Consumer’s interests.
Trackable Telephone Numbers
If a Consumer does not want to have information collected through the Consumer’s use of a trackable telephone number, the Consumer may choose to not call the solar installation company to which the number is assigned by using the trackable phone number displayed on Solar Gen Group Sites.
Response to Do Not Track Signals
Children and Minors
Solar Gen Group Sites are not directed to minors under the age of 16, and we do not intend, and Solar Gen Group Sites are not designed, to collect Personal Information from minors under the age of 16, and we do not knowingly collect Personal Information from minors under age 16. If you are under 16 years old, you should not provide Personal Information to any Solar Gen Group Website. Should we obtain actual knowledge that we have collected or received personal information from a minor under the age of 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under age 16, please contact our Support Department as specified in the " Contact Us" section below.
Solar Gen Group has implemented commercially reasonable administrative, technical, personnel, and physical security measures designed to help protect the Personal Information stored in our systems against loss, theft and unauthorized use, disclosure or modification. For example, we limit access to Personal Information to employees who we believe reasonably need to come into access that information. We also employ processes (such as password hashing, login auditing, and idle session termination) to protect against unauthorized access to Personal Information. Technical measures also include the use of firewall protection. We use TLS (Transport Layer Security) encryption technology to protect Personal Information during transmission. Some of our service providers may store information in servers hosted in countries outside the United States, UK and EU. As such, Personal Information may be subject to the laws of other countries, where the data protection and other laws may not be as comprehensive as those in the United States, UK and EU. Personal Information may be disclosed in response to inquiries or requests from government authorities in the countries in which we operate.
Although Solar Gen Group has endeavoured to create secure and reliable networks, servers and databases that we operate or that are operated on our behalf, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially reasonable means to protect your Personal Information, we cannot guarantee its absolute security and cannot guarantee the protection of all information against interception, misappropriation, misuse, or alteration, or that information may not be disclosed or accessed by accidental circumstances or by the unauthorized acts of others.
Calls and Texting Govern the Collection, Use, Sale, Transfer or Other Disclosure of Personal Information
A Consumer’s Personal Information is collected by a Third Party:
You may revoke your consent and opt-out from receiving automated calls or text messages at any time. You may opt-out of text messages by replying STOP to any text message you receive or follow other opt-out instructions included with the text message. You acknowledge and agree that you may receive a text message confirming your opt-out. To opt-out of automated telephone calls from Solar Gen Group (but not text messages), contact our Support Department as provided below under “Contact Us.” To opt out of receiving automated telephone calls or texts from third parties, please contact the third party directly. Please note that if you opt-out of automated calls, Solar Gen Group and any third parties reserve the right to make non-automated calls to you relating to any transaction or your relationship with Solar Gen Group or the third parties. To obtain assistance from our ConsumerCare Department with respect to text messaging, contact our Support Department as provided below under “Contact Us.”
If you have any questions or need help or assistance regarding privacy, security, opting-out of email or text communications, your email and marketing preferences, or understanding how your Personal Information is being used, please contact our Support Department by email at email@example.com.
Requests to Opt-Out From the Sale of Personal Information
To exercise your right to opt-out from the sale of your Personal Information, you must submit a request to our Support Department by email at firstname.lastname@example.org.
We will act upon your request to opt-out from the sale of your Personal Information within fifteen (15) days after receipt of your request and will notify all third parties to whom your Personal Information was sold, shared, or disclosed within the ninety (90) days prior to receipt of your request that you have exercised your right to opt-out and instruct these third parties to not to further sell, share or disclose your Personal Information. Upon completing these third-party notifications, we will notify you that these third-party notifications have been completed.
Once you make an opt-out request, if we wish to ask you to reauthorize sales of your Personal Information, we will wait at least twelve (12) months before asking you to reauthorize personal information sales.
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
Opting-In To Sale of Personal Information
A Consumer who has exercised the Consumer’s right to opt-out from the sale of the Consumer’s Personal Information, may change the Consumer’s mind and opt back into personal information sales at any time by submitting a request to our Support Department by email at email@example.com. A two-step process will be used whereby the Consumer must first clearly submit the request to opt-in, and then second, separately confirm the Consumer’s choice to opt-in.