Privacy Policy - Luminia

This Privacy Policy describes the types of information we may collect from and about you when you visit the Luminia website (including www.luminia.io), or use the Luminia mobile site to access the Luminia website and technology platform (collectively, the “Services”), and our practices for collecting, using, maintaining, protecting and disclosing that information.

Please read this Privacy Policy carefully to understand how we will treat your information. If you do not agree with our policies and practices, do not use the Services. We may update or change this Privacy Policy. The effective date at the top of this page states when this Privacy Policy was last revised. Any change to this Privacy Policy will become effective when we post the revised Privacy Policy on our Site for our Services. Your use of the Site for our Services means you accept our Privacy Policy and its changes. We encourage you to periodically review this Privacy Policy to stay informed about how we collect, use, and share Personal Information.

If you are an individual and have a Luminia LLC financial product or service for your personal, family or household purposes, please see our Consumer Financial Privacy Notice for additional information about how we use and share Personal Information that we collect in connection with providing you those financial products and services.

QUICK GUIDE TO CONTENTS

INFORMATION WE COLLECT
HOW WE USE YOUR INFORMATION
DISCLOSURE OF YOUR INFORMATION
YOUR CHOICES AND OPTING OUT
SUPPLEMENTAL CALIFORNIA PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
THIRD PARTY CONTENT, LINKS, AND PLUG-INS
CHILDREN’S PRIVACY
DATA SECURITY
CHANGES TO OUR PRIVACY POLICY
CONTACT INFORMATION

1. INFORMATION WE COLLECT

There are several ways that we may collect information about you, including through (A) information you provide to us directly; (B) information that we automatically collect; and (C) information we receive from third parties. This includes data that identifies you personally whether directly (i.e., your name) or indirectly (i.e., information about your online use).

A. Information You Provide To Us

We may collect information directly from you when you provide it to us on the Services. This may include when you use our Services, register or create an online account with us, purchase products or services, request information from us, sign up for newsletters or our email list, fill out a survey, request customer support, or otherwise communicate with or contact us. The information we collect may include your Personal Information which means 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. Personal Information may include your name, postal address, email address, telephone number, referrals, Social Security number, financial information, property or commercial information, tax information, and information about your solar energy activities, such as energy usage or utility provider, or demographic information.

You also may provide us with certain information in connection with your interactions with the Services. If you connect or link to us through a third-party website or service, such as a social media account, we may automatically receive certain information about you based on your registration and privacy settings on those third-party websites or services. This may include, but may not be limited to, your name, user name, demographic information, updated address or contact information, location, interests, and publicly-observed data, such as online activity.

B. Information Collected through Online Activity

Whenever you visit or interact with the Services, we may use a variety of technologies such as cookies, clear GIFs, pixel tags, log files, and other technologies or third-party services (such as LeadID) to automatically collect certain information about users of the Services and interactions with our emails and online advertisements as follows:

Computer or Device Information: We may automatically collect your Internet Protocol (“IP”) address or other unique identifier or information from the computer, mobile device, tablet or other device you use to access the Services, including but not limited to your browser type, device type, system type, and the domain name from which you accessed the Services.
Usage Information: We may collect information about your use of the Services, including the date and time you visit the Services, the content, areas, or pages of the Services that you visit, the website or app from which you navigated to the Services, the page or app you visit after leaving the Services, the amount of time you spend viewing or using the Services, the number of times you return to the Services, as well as other click-stream or usage data, and whether you open, forward or click-through an email to the Services. For legal compliance purposes, we may also capture or record your interactions with www.luminia.io to confirm that your information was submitted to us through www.luminia.io.
Use of Third-Party Analytics and Technologies: We may use third parties’ analytic and tracking tools, such as Google Analytics for Display Marketing, to better understand who is using the Services, how people are using the Services, and how to improve the effectiveness of the Services and their content, and to help us or those third parties serve more targeted advertising to you across the internet. These tools may use cookies, web beacons, pixel tags, log files, Flash cookies, or other technologies to collect and store information about you. They may also combine information they collect from your interaction with the Services with information they collect from other sources. We do not have access to, or control over, these third parties’ use of cookies or other tracking technologies.

To learn more about our interest-based advertising and your advertising choices relating to the collection and use of your information, please see the “How We Use Your Information” and “Your Choices and Opting Out” sections below.

C. Information Collected from Other Sources
We may acquire information from other sources as follows:

From Our Service Providers: We may contract with service providers to support our Services and perform other business processes on our behalf, including, without limitation, to perform credit checks and process credit card payments, consumer reports, credit score and credit history, and we may obtain information from these service providers.
From Our Third Party Trusted Network Partners. We use third parties who are our trusted network partners for business and operational purposes and account management including but not limited to, appraisals, underwriting, verifying information in the application, financing and lending. We may obtain information from these third parties to provide you with the service and/or product to fulfill our contract with you.
From Other Third Parties: We may obtain information about you from other third-party sources, including commercially available sources, such as data aggregators and public databases. This information may include your name, demographic information, utility usage information, solar energy usage information, interests, and publicly-observed data, such as online activity.

We may use this information to help us maintain the accuracy of the information we collect, personalize your experience with the Services, target our communications so that we can inform you of products, services or other offers that may be of interest to you, to measure ad quality and responses, and for internal business analysis or other business purposes.

D. Combination of Information

We may combine the information that we receive from and about you, including information you provide to us and information we automatically collect through the Services, as well as information collected from other online or offline sources, including from third-party sources and from your installed solar system.

2. HOW WE USE YOUR INFORMATION

We may use the collected data for one or more of various purposes:

To fulfill or meet the reason you provided the information. This includes using Personal Information from and about you, on your behalf, to interact with third-party trusted network partners and service providers based on your requests.
To provide and maintain our Services to you.
To analyze, improve, operate, and maintain the Services, our programs, services, and other systems, and to develop new products and services.
To provide you with information, products, or services that you request from us, and to contact and communicate with you when necessary.
To assess the suitability of your property for a solar energy system.
To allow you to take certain actions related to your account, including, but not limited to, tracking the progress of your solar system installation, making and managing payments, viewing billing history, calculating your post-solar savings, reviewing and monitoring your solar production, managing your account and contact information, and viewing and downloading your solar energy system agreement.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including but not limited to, for billing and collection.
To notify you about changes to our Services or any products or services we offer or provide through them.
To provide you with customized content, targeted offers, and advertising on the Services, or across other websites, mobile applications, social media or online services, or via direct mail, email, and/or telemarketing regarding offers, contests, events, news, programs, and other retail opportunities from us and/or selected third parties that we believe may be of interest to you.
To determine the effectiveness of our marketing programs.
To detect, prevent and address technical issues;
To monitor the usage of our Service;
To provide customer support, and address and remedy any inquiries or complaints made by or about you related to our Services;
To gather analysis or valuable information so that we can improve our Service.
To use your data in an aggregated non-specific format for analytical and demographic purposes.
To exercise our rights and to protect our and others’ rights and/or property including to take action against those that seek to violate or abuse our Services.
For internal business purposes.
To comply with the law and legal obligations, including to respond to a request or order from a court, regulator, law enforcement, or authority, and in connection with litigation, and/or to comply with regulatory record retention requirements.
Effectuate the sale, merger, acquisition, or other disposition of the business, including in connection with any bankruptcy or similar proceedings. In any other way we may describe when you provide the information to us.

3. DISCLOSURE OF YOUR INFORMATION

We may share your Personal Information that we collect for business or commercial purposes as follows:

Service Providers: We may contract with service providers that we use to support our business and Services, perform Service-related services or assist us in analyzing how our Service is used. Examples may include technology platform services, data processing, billing and collections, customer service, electronic signature services, and other data collection as part of our business. These service providers have access to your information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Third Party Trusted Network Partners: We may share your information with third party trusted network partners, with your consent and as permitted by law, to perform vital functions for our business and operational purposes and account management including but not limited to, appraisals, underwriting, verifying information in the application, financing and lending. These network partners have access to your information to perform related services to help us provide you with products and/or services that you request, and are legally required to keep your information confidential.
Sale or Transfer of Business or Assets: We may sell or purchase assets during the normal course of our business. If another entity acquires us or any of our assets, information we have collected about you may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be among the assets transferred.
Marketing Partners and Other Third Parties: Luminia may share your information with our online and email advertisers or other third-party vendors we use who may provide cookies, pixel tags, web beacons, clear GIFs or other similar technologies for use on our Sites or other websites to manage and improve our online and email advertising campaigns.
Compliance with Laws: We may access and disclose your information with regulatory authorities or governmental agencies to comply with any court order, law, or legal process, including responding to any subpoenas, judicial processes, or government or regulatory requests and investigations.
Enforcing Our Rights: We may disclose your information to enforce or apply our terms of service (see www.luminia.io/terms-of-service) and other agreements, including for billing and collection purposes, in connection with a claim or dispute, or to protect the security of our Services, servers, network systems, and databases.
Safety: We may access and disclose your information if we believe disclosure is necessary or appropriate to protect our rights, property, or safety, or the rights, property, or safety of our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Aggregate or Anonymous Non-Personal Information: We may share aggregate, anonymous, or de-identified non-personal information with third parties for their marketing or analytics uses.
Other: We may share your information as described to you at the point of collection.

4. YOUR CHOICES & OPTING OUT

A. Cookies, Tracking Options and California Do Not Track Disclosures

Certain parts of our Services require cookies. Cookies are small text files placed on your web browser when you visit our Site that store information on your computer, such as your Site preferences. We use cookies when you sign in to keep track of your personal session, including some account identifiers to ensure you are the only person making changes to your account. We may use cookies or other technologies to deliver more relevant advertising and to link data collected across other computers or devices that you may use.

You may adjust your device or Internet browser settings to limit certain tracking or to decline cookies, but by doing so, you may not be able to use certain features on the Services or take full advantage of all of our offerings. Please refer to your device’s settings or your Internet browser’s “Help” section for more information on how to delete and/or disable cookies or to control your tracking preferences.

Our system may not recognize “do not track” requests or headers from some or all browsers.

B. Interest-Based Advertising Choices

To understand your choices for receiving more relevant advertising provided on the Service or across other websites and online services, please review the information below:

To learn more about such interest-based advertising, and to opt out of such collection and use for interest-based advertising by the Digital Advertising Alliance (DAA) participating companies, please visit http://www.aboutads.info/choices/.
To opt out from the use of information about your online activities for interest-based advertising by Network Advertising Initiative (NAI) member companies, please
visit http://www.networkadvertising.org/choices/.
To opt out of the use of your mobile device ID for targeted advertising, please see http://www.aboutads.info/appchoices.
If you wish to prevent your data from being used by Google Analytics, Google has developed the Google Analytics opt-out browser add-on available
at https://tools.google.com/dlpage/gaoptout/.
On your mobile device, you may also adjust your privacy and advertising settings to control whether you want to receive more relevant advertising including turning off the device’s location tracking on your mobile device depending on your specific device. Even if you opt out, you still may receive advertising from us that is not customized based on your Service or usage information, or advertising from third parties if they are not a DAA or NAI participating company.

C. Unsubscribing from Our Marketing Communications

We provide our customers, as well as individuals referred by our customers, with the opportunity to opt out of having their information used for purposes not directly related to placement, processing, fulfillment, or delivery of a product or service.

To opt out of marketing communications or to request to be added to our Do Not Call List or Do Not Mail List, you may use one of these convenient methods:

Email Offers: If you receive commercial email from us, you may unsubscribe at any time by following the instructions contained within the email, or by sending us an email or writing to us at the addresses listed below. You should note that unsubscribing from our emails will not automatically unsubscribe you from emails sent by any third party, and you will need to separately unsubscribe from such third party’s communication, if desired.
Direct Mail Offers: If you do not wish to be notified by postal mail regarding products, services, events, programs, and offers that we believe you may find of interest, send us an email or write to us at the addresses listed below.
Telemarketing: If you do not want to receive marketing phone calls from us, you may: (i) email us at privacy@luminia.io with “Do Not Call” in the subject line; (ii) call us at the toll- free number at 800-675-0632 (iii) ask to be placed on our Do Not Call list when you receive a call from us; or (iv) mail us at the address listed below in the “Contact Information” section 10. Once we place your name on our internal “Do Not Call” list, we will no longer call you for marketing purposes (unless you submit another inquiry or request another consultation/quote from us after your initial do-not-call request). We will honor your request as soon as reasonably practicable. You may still receive calls from third parties who are not calling on our behalf regarding their products and services, and you will need to separately request that those parties not call you.

Any third parties to whom we may disclose your information may have their own privacy policies which describe how they use and disclose your information, and your choices. If you want to learn more about their privacy practices, we encourage you to visit the websites of those third parties.

D. Accessing or Updating Your Information

If you become a Luminia customer, you can create an account with us. You can contact your sales representative or Luminia Customer Care representative to request a correction to or update of certain information you provided in connection with your account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

5. SUPPLEMENTAL CALIFORNIA PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

This Supplemental California Privacy Notice provides additional information on how we manage Personal Information that we receive from consumers who are residents of California under the California Consumer Privacy Act of 2018 (“CCPA”). These rights may be limited in some circumstances by local law requirements.

When we use the term “Personal Information” in this Supplemental California Privacy Notice, we mean 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. Any other terms defined in the CCPA have the same meaning when used in this Supplemental California Privacy Notice.

Please note that the definition of Personal Information does not include information that is publicly available, information that has been de-identified or aggregated, or information exempt from the purview of the CCPA, such as:

Personal Information regulated by certain industry-specific privacy laws, such as the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994. Accordingly, the rights under the CCPA do not apply to Personal Information collected, processed, sold or disclosed pursuant to these industry-specific privacy laws.
Protected Health Information (“PHI”) governed and protected by the Health Insurance Portability and Accountability Act of 1996 (HIPAA), and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data.

Personal Information We Collect

Please see above section “1. INFORMATION WE COLLECT”.

In the preceding twelve (12) months, we have collected the following categories of Personal Information from consumers, which we may have shared for a business purpose, as permitted or required by law:

Categories	Examples	Collected	Purpose for Collection
Identifiers	A real name, Internet Protocol address, email address, or other similar identifiers.	YES	Business purpose

Categories

Examples

Collected

Purpose for Collection

Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some Personal Information included in this category may overlap with other categories.

YES

Business purpose

Protected classification characteristics under California or federal law

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Not applicable

Commercial information

Records of personal property, commercial property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies; solar and energy usage information.

YES

Business purpose

Biometric information

Genetic, physiological, behavioral, and biological characteristics or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Not applicable

Geolocation data

Physical location or movements.

Not applicable

Sensory data

Audio, electronic, visual, thermal, olfactory, or similar information.

Not applicable

Professional or employment- related information

Current or past job history or performance evaluations.

YES

Business purpose

Categories

Examples

Collected

Purpose for Collection

Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Not applicable

Inferences drawn from other Personal Information

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Not applicable

B. Purposes for Collection, Use, and Disclosure of Personal Information

Please see above section “2. HOW WE USE YOUR INFORMATION”.

We may also use or disclose your Personal Information in accordance with your consent, when required by law to do so, as permitted by law, or if it is necessary for a corporate transaction (such as a merger or acquisition).

C. Disclosure of Personal Information

Please see section above: “3. DISCLOSURE OF YOUR INFORMATION”. We may share the information we collect as described in this Privacy Policy and Supplemental California Privacy Notice.

D. California Rights and Choices under the CCPA

The CCPA provides California residents with certain rights regarding their Personal Information that is collected about them, subject to certain limitations at law. The following section describes your CCPA rights and explains how to exercise those rights.

Right to Access and Portability

California residents have the right to request that we disclose certain information about our collection and use of Personal Information in the preceding twelve (12) months. Once we receive and confirm your verifiable consumer request, in which we may have to gather further identifiable information in order to confirm your identity, we will disclose to you the following:

The categories of Personal Information we collected about you;
The categories of sources for the Personal Information we collected about you;
Our business or commercial purpose for collecting and using that Personal Information;
The categories of third parties with whom we share that Personal Information;
The specific pieces of Personal Information we collected about you (also called a data portability request); and
If we disclose your Personal Information for a business purpose, identifying the Personal Information categories disclosed.

We will deliver a verifiable access request and the accompanying information to you in a portable, easily readable electronic format or by mail.

Right to Deletion

The CCPA allows California residents the right to request that we delete any Personal Information about you that we collect and retain, subject to certain exceptions described below. Once we receive and confirm your verifiable consumer request, in which we may have to gather further identifiable information in order to confirm your identity, we will delete (and in turn direct our service providers to delete, if applicable) your Personal Information from our records, unless an exception applies.

We may deny a deletion request if retaining the information is necessary to:

Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity;
Debug products to identify and repair errors that impair existing intended functionality;
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Enable solely internal uses that are reasonably aligned with consumer expectations;
Comply with a legal obligation and requests from law enforcement agencies; and
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to Opt-Out of the Sale of Your Personal Information

We do not sell Personal Information and in the preceding twelve (12) months, have not sold any Personal Information.

You have the right to request to opt-out of the sale of your Personal Information to third parties. We will not sell Personal Information without providing you with prior notice and an opportunity to opt-out as required by law.

Submitting a Verifiable Consumer Request

To exercise the access and deletion rights under the CCPA as described above, please submit a verifiable consumer request by contacting us: Via Email to privacy@luminia.io, or by calling us at the toll-free number 800-675-0632.

For verification purposes, please provide your name, address, telephone number and email address. Further information may be required for verification.

A verifiable consumer request may be submitted by a California resident or a person registered with the California Secretary of State that is authorized to act on your behalf. These requests for access, which can only be made twice during a twelve-month period, and deletion must:

Detail sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

Submitting a Request Through Your Authorized Agent

In order to submit a verifiable consumer request through an authorized agent, the authorized agent must identify that such request is being made through an authorized agent and provide all of the required information for a verifiable consumer request, as well as proof of authorization signed by the consumer who is the subject of the request. We may also contact the California consumer directly to verify the request.

Timeframe for Responding to Verifiable Consumer Requests

We will respond to your verifiable consumer request within forty-five (45) calendar days of receipt, after proper verification, unless we need additional time, in which case we will let you know.

The period of response may be extended to sixty (60) or ninety (90) days if more time is required. In that event, we will inform you of the reason and extension period in writing.

Fee

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.

No Discrimination

The CCPA prohibits a business from discriminating against California residents for exercising the CCPA rights outlined above. We will not discriminate against you for submitting such requests.

No Financial Incentive

We do not offer any financial incentives or price or service differences in an attempt to influence a consumer’s decision whether or not to exercise a right afforded to the California consumer under the CCPA.

6. THIRD-PARTY CONTENT, LINKS, AND PLUG-INS

The Services may contain links to third parties who partner with us. If you use those links, these third parties may collect information about you. We do not control third-party links or how these third parties collect and use your Personal Information, and are not responsible for the practices of those third-parties. If you have any questions about their privacy practices, you should view their privacy policies and/or contact those third parties directly.

7. CHILDREN’S PRIVACY

Protecting children’s privacy is important to us. We do not direct the Services to, nor do we knowingly collect any Personal Information from, children under the age of sixteen. If you are a parent or guardian and believe your child has provided us with Personal Information without your consent, please contact us by using the information in the “Contact Information” section 10 below. If we learn that a child under the age of sixteen has provided Personal Information to the Services, we will use reasonable efforts to remove such Personal Information from our files.

8. DATA SECURITY

We have implemented measures designed to secure your information from accidental loss and from unauthorized access, use, alteration, and disclosure. We limit access to the Personal Information we have about you to those employees who have a legitimate business need to access such information. We use encryption technologies to safeguard your Personal Information. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to ensure the integrity and security of our network and systems, we cannot guarantee our security measures. Please remain careful and vigilant in your online activities.

9. CHANGES TO OUR PRIVACY POLICY

This Privacy Policy is subject to change. We will post any changes to our Privacy Policy here, as well as provide a notice of the update on the Services home pages. If we make material changes that allow us to use your Personal Information in a less restricted way, we will make reasonable efforts to notify you. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting the Services to check for updates to the Privacy Policy. Your continued use of the Services after we change the Privacy Policy means you accept those changes.

10. CONTACT INFORMATION

To ask questions or comment about this Privacy Policy and our privacy practices, please contact us:

Via U.S. Mail: Luminia LLC, Attn – Marketing (Privacy), 4445 Eastgate Mall, Suite 200, San Diego, CA 92121
Via Email to: privacy@luminia.io
Via our Toll-Free number: 800-675-0632