Inspire Privacy Policy

Last Updated: October 01, 2021

I. What does this Privacy Notice cover

This Privacy Notice sets out what personal information we collect, for what purposes and your rights in this respect.

This Privacy Notice provides you with information on the processing of your personal information by Inspire Energy Holdings, LLC, Inspire Digital Services USA, and our affiliates, whether as:

We are committed to protecting the privacy and security of your personal information. This Privacy Notice explains, amongst other things, what personal information we process, for which purposes we process your personal information, with whom we share your personal information, for how long we hold your personal information for, how to access and update your personal information and where to go for further information or to lodge a complaint.

If you would like to receive this Privacy Notice in an alternative format (for example, in larger print) or if you have any questions about our processing of your personal information which are not answered by this Privacy Notice, please contact us at help@inspirecleanenergy.com or call us at 866-403-2620.

We do not sell your information
We will not sell or otherwise provide your personal information to third parties for their commercial purposes. Our employees and any third-party service providers utilized by us are contractually obligated to protect the privacy and confidentiality of your personal information.

II. Special Notice - Children’s personal information

We do not knowingly collect, maintain, use or process personal information from individuals under the age of 13 and no part of our websites or services are directed to children. If you are under 13 years old please do not send us your personal information; for example, your name, address and email address. If you wish to contact us in a way which requires you to submit your personal information (such as for education or innovation events) you must get your parent or guardian to do so on your behalf.

If you are aware of or know that a child the age of 13 has provided us with personal information in violation of this Privacy Notice, then you may alert us at help@inspirecleanenergy.com

III. Who is responsible for any personal information collected

Inspire Energy Holdings LLC will be responsible for processing your personal information, either solely or jointly with our affiliates within the Shell group of companies.

IV. What personal information do we process

The categories of personal information we process.

We collect personal information about you as a customer or visitor to our websites. This may include:

Personal information that you provide to us: in using or purchasing our services, products or websites, you may provide us with personal information, including without limitation:

Personal information we may automatically collect about you: our services and websites may automatically collect certain personal information about you. This personal information may be used to help us design our services and websites to better suit your needs. This personal information may include any of the following:

Personal information that we obtain through your use of our services: we will also collect personal information about your use of our services and products, as well as third-party applications, programs and / or devices that you connect to our services. These devices may include smart lightbulbs, such as those made by Sengled, smart thermostats, such as those made by Ecobee and Nest, smart cameras, smart locks, and smart doorbells. When you choose to integrate a device with our services, the device will provide us with access to some or all of your personal information on that device, such as the device name or identifier, meter readings, energy consumption data and history, electronic device information, IP addresses, log information, browser type and preferences, general location information, device usage information and usage history, photos and/or videos captured by the device, device state, user controls and actions, weather, and temperature settings.

We use this personal information to operate, maintain, and provide to you the features and functionality of our services and products, including tracking your energy usage to provide smarter energy consumption by building a profile of your routines and preferences so that we may provide you with recommendations on decreasing or shifting your energy consumption and using your devices more efficiently. We may also use this personal information for our internal analytics and research purposes, such as improving our forecasting models for electricity usage and operating and improving our services and products. You should review information from the devices, including their privacy policies and terms of use, prior to using them or allowing them access to any of your personal information.

These devices are not sold, designed or manufactured by Inspire Energy Holdings, LLC or our affiliates, and we do not warrant and are not responsible for the quality, use or operation of these third-party devices. Your use of these devices is governed by separate terms of use and privacy policies by the third-party device providers

Personal information we receive from third parties:

Personal information in relation to individuals who are, or who work for or on behalf of, our Shareholders, Business Customers, Suppliers, and Partners:

V. What is the lawful basis for processing your personal information

The personal information covered by this Privacy Notice is only processed:

Where the processing is based on consent, you have the right to withdraw your consent at any time. This will not affect the validity of the processing prior to the withdrawal of consent.

VI. For what purposes do we process your personal information

We only process your personal information where we have a lawful basis and purpose to do so.

We process your personal information for the purposes of:

We may also process your personal information for a secondary purpose where it is closely related, such as:

Communication and Marketing

When you opt-in to receive SMS messages from us, we will send you an SMS message to confirm your sign-up for Inspire notifications. By opting into any Inspire text program, you expressly consent to receive text messages that may be sent using an automatic telephone dialling system, by or on behalf of Inspire Energy Holdings, LLC and our affiliates, at the phone number you provide. Consent to receive texts is not a condition of purchasing any products or services.

You can cancel the SMS service at any time by texting “STOP”. We will send you an SMS message to confirm that you have been unsubscribed. After this message, you will no longer receive SMS messages from us. If you want to start receiving SMS messages again, reply “START” to any of our messages or contact our Member Experience Team at help@inspirecleanenergy.com or call us on 866-403-2620 to be resubscribed.

Screening
In addition, in order to comply with legal and regulatory obligations, to protect our assets and employees/contractors and specifically to ensure that we can comply with trade control, anti-money laundering and/or bribery and corruption laws and other regulatory requirements, we carry out screening (pre-contract and on a periodic basis post-contract) on owners, shareholders and directors of our business customers, suppliers and business partners. This screening takes place against publicly available, or government issued sanctions lists and media sources.

The screening does not involve profiling or automated decision making in relation to the counterparties or potential counterparties.

VI. What are the consequences of not providing your personal information

Personal information gathered by us for these processes either directly or indirectly is required in order to:

Failure to provide us with the information required will negatively affect our ability to communicate with you, or our ability to enter a contract with a counterparty or continuing to contract with a counterparty.

VII. Who will we share your personal information with

Your personal information may be shared with:

Shell Single View of the Customer

With the aim of ensuring you have a seamless experience with the Shell group and depending upon the nature of your engagement with Shell, we combine information gathered from the sources referred to above to create a personal profile of you. This enables you to interact with different Shell companies more easily and ensures we have the most up to date information about you in order to better develop services and products and to tailor offers relevant to your specific interests.

Please note however, you can control how Shell uses this information. You can opt out of having your personal information combined in this way. For further details please refer to section ‘Your rights in relation to your personal information’.

The creation of a personal profile does not involve profiling or automated decision-making processes

VIII. Transfers of your personal information to other countries

Your personal information may be transferred outside of your country, subject to appropriate safeguards.

Where your personal information is transferred to companies within the Shell group and/or to authorized third party agents service providers and/or subcontractors who may be located in or outside of your location we take organizational, contractual and legal measures to ensure that the personal information is processed for the purposes mentioned above and that adequate levels of protection have been implemented in order to safeguard the personal information.

These measures include Binding Corporate Rules for transfers among the Shell Group and European Commission approved transfer mechanisms for transfers to 3rd parties in countries which have not been deemed to provide an adequate level of data protection as well as any additional local legal requirements. You can find a copy of the Shell Binding Corporate Rules at https://www.shell.com/privacy.html

IX. Security of your personal information

We are committed to safeguarding your personal information.

We have implemented technology and policies with the objective of protecting your privacy and personal information from unauthorized access and improper use. In particular, we may use encryption for some of our services, we apply authentication and verification processes for access to our services and we regularly test, assess and evaluate the effectiveness of our security measures. However, as no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your personal information.

X. How long do we hold your personal information for

We hold your personal information for a limited period.

We take measures to only store your personal information for as long as is necessary to fulfil the purposes outlined in this Privacy Notice or for as long as we reasonably consider necessary to establish, exercise or defend our legal rights. Your personal information will be retained in line with statutory and regulatory requirements. When determining the specific retention period, we consider various factors, such as the type of service provided to you, the nature and length of our relationship with you, and mandatory retention periods provided by law and the statute of limitations.

In all cases personal information may be held for a) a longer period of time where there is a legal or regulatory reason to do so (in which case it will be deleted once no longer required for the legal or regulatory purpose) or b) a shorter period where the individual objects to the processing of their personal information and there is no longer a legitimate purpose to retain it.

XI. Your rights in relation to your personal information

Your rights and how to exercise them.

We aim to keep our information as accurate as possible. You can request:

To make a verifiable rights requests please email us at help@inspirecleanenergy.com or call 866-403-2620

The verifiable request must:

We cannot respond to your request unless we can verify your identity or if you are an authorized agent, your authority to make the request on behalf of the consumer. We will aim to verify your identity based on personal information we already hold about you. If we need to request further information from you in order to verify your identity, we will only use that personal information for the purposes of identifying you or that you have authorized the request.

Note that there are exceptions and limitations to each of these rights, and that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain personal information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so, such as completing a transaction for which the personal information was collected or to comply with a legal obligation such as financial reporting. However, the personal information will be deleted once no longer needed for that purpose in line with the time periods set out above.

XII. Who to contact if you have a query, concern or complaint about your personal information

If you have any issues, queries or complaints regarding the processing of your personal information, please contact us at: help@inspirecleanenergy.com or call 866-403-2620.

Since we are part of the Shell Group, you may also contact the Shell Group Chief Privacy Office at Shell International B.V. The Hague, The Netherlands - Trade Register No. 27155369 Correspondence: PO Box 162, 2501 AN, The Hague, alternatively you can also email the Shell Group Chief Privacy Office at privacy-office-SI@shell.com

If you are unsatisfied with the handling of your personal information by us, you have the right to lodge a complaint to the Shell Group regulator which is the Dutch Data Protection Authority located at Prins Clauslaan 60, 2595 AJ The Hague, The Netherlands. Please visit https://autoriteitpersoonsgegevens.nl/en for more information.

You also have the right to lodge a complaint to your local data privacy authority/regulator.

XIII. Changes to this Privacy Notice

This Privacy Notice may be updated over time.

This Privacy Notice may change over time and you are advised to regularly review this Privacy Notice for possible changes. This Privacy Notice was last updated on 1st October 2021.

XIV. California Consumer Privacy Rights (“CCPA”)

For the avoidance of doubt, all of the aforementioned provisions in the Privacy Notice apply to all consumers whose personal information is processed by Inspire Energy LLC in the United States of America regardless of state of residency. These rights are without prejudice to any additional rights you may have in line with local law.

Accordingly, in addition to the information and rights set out in this Privacy Notice (See section entitled ‘Your rights in relation to your personal information’), California residents also have the following rights:

As a matter of principle, Inspire Energy LLC does not sell the personal information of any individual whose information is processed by us.

How to Exercise your Rights under CCPA

If you would like to submit a request, please fill out our Request Form or call us toll free at (888) 914-9661, pin 898341

If you complete our form, it must be completed accurately and completely before we can respond. If you choose to submit a request, you must provide us with enough information to identify you and enough specificity on the requested personal information. We will only use any personal information we receive for verification purposes. We will not be able to disclose information if we cannot verify that the individual making the request is the individual about whom we collected personal information, or someone authorized to act on such individual’s behalf. An authorized agent may submit a request on your behalf by sending a written authorization signed by you to help@inspirecleanenergy.com. We may still require you to directly verify your identity and confirm that you provided the authorized agent permission to submit the request.