Privacy Policy

PRIVACY POLICY

Last Updated: 8/7/2025

This policy explains the rights of California residents regarding the collection, use, sale, and sharing of their personal information under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). We may update and make changes to this policy, so we encourage you to review it periodically.

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

We, us, our	Cohen Ventures, Inc., dba Energy Solutions
Our representative	Diane Walker – dwalker@energy-solution.com
Personal information	Any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular consumer or household.
Sensitive personal information	Personal information revealing a consumer's racial or ethnic origin

Personal Information We Collect About You. In the preceding 12 months, we have collected the following categories and specific types of consumer personal information:

Categories of Personal Information	Specific Types of Personal Information Collected
Identifiers (e.g., a real name, postal address, email address, or other similar identifiers)	Name, address, email address, phone number, and Service Agreement ID (SA ID)
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, and employment.	Name, address, email address, phone number, and Service Agreement ID (SA ID)
Characteristics of protected classifications under California or federal law	Racial or ethnic origin, age range, and gender
Professional or employment-related information	Employment status
Sensitive Personal Information	Racial or ethnic origin

How Your Personal Information is Collected. We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website and apps, as well as from the San Francisco Public Utilities Commission.
Why We Use Your Personal Information. We collect consumer personal information for the following business purposes:

Determining your eligibility for the coupon to be presented to participating dealers
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;
Debugging to identify and repair errors that impair existing intended functionality;
Performing services on behalf of Cohen Ventures, Inc., dba Energy Solutions and the San Francisco Public Utilities Commission, 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 the business or service provider;
Undertaking internal research for technological development and demonstration;
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business;
To comply with our legal and regulatory obligations;
For the performance of our services provided to you or to take steps at your request before providing those services;
To prevent or detect against fraud; or
Where you have given consent.
We do not give, share, sell, or transfer any personal information to a third party.
We will not give or sell your individual information to any outside company for its use in marketing or solicitation.

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 services to you	For the performance of our contract with you or to take steps at your request before providing services to you
To prevent and detect fraud against you or Cohen Ventures, Inc., dba Energy Solutions	For our legitimate interests to minimize fraud that could be damaging for us and for you
Conducting checks to identify our customers and verify their identity Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g., under health and safety regulation or rules issued by our professional regulator	To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, enquiries, or investigations by regulatory bodies	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g., policies covering security and internet use	For our legitimate interests, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training, and quality control	For our legitimate interests, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests, i.e., to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations
Preventing unauthorized access and modifications to systems	For our legitimate interests, 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	For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests, e.g., making sure that we can keep in touch with our customers about existing orders and new products
External audits and quality checks, e.g., for accreditations and 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

We do not give, share, sell, or transfer any personal information to a third party. We will not give or sell your individual information to any outside company for its use in marketing or solicitation.
How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:

To respond to any questions, complaints or claims made by you or on your behalf;
To show that we treated you fairly; or
To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy.

When it is no longer necessary to retain your personal information, we will delete or anonymize it.

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; Our business or commercial purpose for collecting, selling, or sharing personal information; 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.
Right to Limit Use of Sensitive Personal Information	You have the right to limit the use 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 the business, 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 the business; (3) Performing services on behalf of the business, 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 the business; 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 the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business; 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. To limit the use of your sensitive personal information, please email privacy@energy-solution.com.
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 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.

How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, you can do so by emailing us at privacy@energy-solution.com. You may also call us at 888-560-2422.
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 or 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 your request will be used solely for the purposes of verification.