Privacy Policy

Last updated: March 1, 2025

JadeTrack, LLC and its affiliates (“JadeTrack,” “we,” “us,” “our”) respects your privacy. This Privacy Policy (the “Privacy Policy” or “Policy”) describes how we collect, use, and disclose your Personal Information (as defined below) and how to exercise any rights you might have with respect to this information.

Please read this Policy, which is part of our website Legal Terms, before using our Sites and/or Services. By Accessing or using our Sites and/or Services you agree to our use of your information consistent with the Terms of Use and this Policy, subject to your rights described below.

Table of Contents

About This Privacy Policy

Applicability

This Privacy Policy governs information we collect through our website(s), microsite(s), mobile website(s), and mobile applications (collectively, “Sites”) and information we collect from you or third parties through any other means to provide our services or perform other business activities (collectively, “Services”). It does not apply to Personal Information we collect from or about job applicants, employees, or independent contractors. 

Privacy Policy Changes

This Privacy Policy is subject to change. It is your responsibility to review the Policy for any revisions or amendments. Unless otherwise stated, changes will be effective immediately upon posting and you accept the changes by continuing to use our Sites or Services. If we determine that a change will result in using previously acquired Personal Information in a materially new way, we will: (1) Provide you notice before such use; and (2) Take any other action necessary under applicable law.  You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you.. The date we last revised the Privacy Policy is identified at the top of the page.

Conflict Between This Policy and Local Laws and Regulations

When federal, state, and local laws and regulations require a higher level of protection for your Personal Information, they take precedence over this Privacy Policy.

Information We Collect

Personal Information

We may collect information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Information”). The type of Personal Information we collect about you may vary based on how you use our Sites and/or Services and your relationship with us but may include:

  • Identifiers such as name, mailing address, service address, email addresses, phone numbers, or JadeTrack login information;
  • Characteristics of protected classifications under California or federal law such as age, marital status, gender;
  • Other demographic information such as the language(s) you speak;
  • Commercial information such as payment card or bank account information, the type(s) of service subscribed to, equipment information, energy consumption or production, service dates, customer type, contract terms, account balance, and status, your utility company and account number, details about energy-related equipment used in the building;
  • Internet or other electronic network activity information such as browsing/search history, IP address, device information such as device IDs, specifications, operating system, and other data collected through Cookies;
  • Geolocation data such as non-precise geographic location indicators from devices, service addresses, signed contracts;
  • Audio, electronic, visual, thermal, olfactory or similar information such as call recordings, chat transcripts, email correspondence, and testimonials;
  • Professional/employment information such as employer, occupation; and
  • Inferences drawn from other Personal Information or data that relate to your preferences, interests, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes, including credit reports and scores;

We may collect information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Information”). The type of Personal Information we collect about you may vary based on how you use our Sites and/or Services and your relationship with us but may include:

  • Identifiers such as name, mailing address, service address, email addresses, phone numbers, or JadeTrack login information;
  • Characteristics of protected classifications under California or federal law such as age, marital status, gender;
  • Other demographic information such as the language(s) you speak;
  • Commercial information such as payment card or bank account information, the type(s) of service subscribed to, equipment information, energy consumption or production, service dates, customer type, contract terms, account balance, and status, your utility company and account number, details about energy-related equipment used in the building;
  • Internet or other electronic network activity information such as browsing/search history, IP address, device information such as device IDs, specifications, operating system, and other data collected through Cookies;
  • Geolocation data such as non-precise geographic location indicators from devices, service addresses, signed contracts;
  • Audio, electronic, visual, thermal, olfactory or similar information such as call recordings, chat transcripts, email correspondence, and testimonials;
  • Professional/employment information such as employer, occupation; and
  • Inferences drawn from other Personal Information or data that relate to your preferences, interests, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes, including credit reports and scores;

Some of the Personal Information listed above may qualify as “Sensitive Personal Information” under relevant privacy laws. This includes JadeTrack account login credentials. Additionally, some of the Personal Information listed above may qualify as “personal information” as defined in Cal. Civ. Code § 1798.80(e).

Usage Data and Site Activity

We automatically collect information in connection with the actions you take on our Sites (“Usage Data”), including:

  • Web service information such as the type of web browser you use, and your internet service provider;
  • Device information such as the type of device you use your device ID, your operating system and version, and your IP address; and
  • Web activity information such as the pages you view, referring and exit pages, the date and time of your visit, and the number of clicks to, from, and within our Sites, and the duration of your visits to our Sites.

Among other things, this data helps us estimate our audience size and usage patterns, recognize you when you return to our Sites, store information about your preferences, customize our Sites according to your interests, and speed up your searches. If the data we automatically collect is capable of being associated with you, directly or indirectly, we treat it as Personal Information, otherwise, we treat it as Usage Data.

Communication Recordings

We may record calls and retain the content of text messages, emails, chat transcripts, and other written or electronic communications between you and us. By communicating with us, you consent to our recording and retention of communications.

How We Collect Information

From You

We may ask you to provide us with Personal Information when you communicate with us online or offline, including web forms, events, surveys, and marketing or promotional programs. You are not required to provide us your Personal Information; however, if you choose not to provide the requested information, you may not be able to use some or all of the features of our Sites or Services or we may not be able to fulfill your requested interaction. We may also capture your contact information, such as phone numbers and email addresses, when you contact us.

Third-Party Data Sources

We may collect Personal Information from third-party data sources such as data brokers, marketing and sales agencies or partners, analytics firms, government agencies, utilities, other customers or consumers, and credit reporting agencies.

Cookies and Targeted Advertising

Cookies and Automated Tools

We and third parties may use cookies (small text files placed on your computer to identify your computer and browser), log files, web tags, beacons, pixels, session recordings, embedded scripts, and other automated tools (collectively “Cookies”) to track your interaction with our Sites and Services, improve the experience of our Sites and Services, and conduct cross-context behavioral or targeted advertising (collectively “targeted advertising”)..

We may use the following types of Cookies:

  • Strictly Necessary: These Cookies are essential to operate the Sites and provide you with services you have requested.
  • Functional: These Cookies enable certain features or non-essential functionality on our Sites. For example, we might use these Cookies to recognize you and remember your preferences or settings when you return to our Sites so we can provide you with a more personalized experience.
  • Advertising: These Cookies allow us and third parties to learn more about you, including your use of our Sites and other websites, and advertise products or services that might interest you as further indicated below.
  • Analytics: These Cookies help us and third parties understand how our Sites are working and who is visiting our Sites.

If you arrive at our Sites by “clicking through” from another website, that website may provide certain information about you such as the search terms that led you to our Sites. You should review the privacy policy of any website from which you reached our Sites to determine what information the operator collects and how it uses such information.

Targeted Advertising

We may work with third-party advertisers, search providers, and ad networks (“Advertisers”) to learn more about you and show you ads or other content that we believe would be relevant to you. Advertisers may collect and use information about your use of our Sites or Services as well as other websites and services. These companies may use Cookies to collect and use your information. We and/or Advertisers may also append other data to the data collected by Advertisers to create an interest profile of individual users. Our Privacy Policy does not cover any use by an Advertiser of information that they may collect from you. Advertisements may be shown via our Sites or on third-party websites. Some Advertisers are members of the Digital Advertising Alliance (DAA) or Network Advertising Initiative (NAI), which maintain websites where people can opt-out of targeted advertising from their members. If you want to reduce the targeted advertising you receive, you can visit the DAA Consumer Choice Page and/or NAI Consumer Opt-Out Page. These opt-outs may be device and browser specific.

Social Media Widgets

Our Sites may include social media features, such as the Facebook, YouTube, Instagram, LinkedIn and X widgets. These features may collect information about your IP address and the pages you visit on our Sites as well as other Personal Information. A Cookie may be set to ensure that these features properly function. These companies’ privacy policies govern your interactions with these features and you should review the relevant privacy policies before interacting with these features.

How We Use and Disclose Information

Generally

We may use Personal Information for business purposes, such as:

  • Account creation, fulfillment, servicing and customer support: to process applications, create customer accounts, allow customers to create online accounts and profiles, provide goods or services, engage in general customer service operations, or to otherwise fulfill the purpose for which you provide your information;
  • Marketing and market research: to market our and third parties’ products and services, perform analytics, and conduct market research;
  • Customer communications and interactions: to administer surveys, provide newsletters or announcements, keep customers informed about the status of their products and services, or to otherwise communicate and interact with customers and consumers;
  • Website use and analytics: to provide you with access to and use of our Sites and Services, analyze consumers’ use of our websites, including the use of third-party web analytics services, which may utilize Cookies to collect data;
  • Eligibility and pricing: to determine if consumers are eligible for certain products, services, or offers and the pricing related to such offers;
  • Product research: to conduct research and analysis for maintaining, protecting, and developing services, increase and maintain the safety of our products and services, and prevent misuse;
  • Business operations: to evaluate, develop, and improve business operations, products and services offered, carry out our obligations and enforce our rights arising from any contracts entered into between you and us, perform business administration and other normal business activities;
  • Compliance: to comply with applicable legal requirements, industry standards, contractual obligations, our policies, and take actions that we deem necessary to preserve and enforce our rights and the rights of others; and
  • Information security and fraud prevention: to operate information security and anti-fraud programs.

We use Sensitive Personal Information as follows:

  • Account login information – to permit access to customers’ online accounts, and in connection with our security and anti-fraud programs.

We may also use Personal Information and/or Sensitive Personal Information as described to you at the point of collection, with your consent, or as otherwise required or permitted by applicable laws. We only use Sensitive Personal Information related to California residents for purposes that do not trigger opt-out rights under California law

Reviews and Testimonials

If you provide a review or testimonial, we may post it publicly on our Sites or in other advertising material. By providing a testimonial, you give us permission to use it in any manner and for any purpose, including in marketing and advertising communications.

Marketing Opt-Outs

If you do not want us to use your Personal Information for certain marketing purposes, you may take advantage of applicable opt-out options such as checking the relevant box located on the form on which we collect your information, adjusting your user preferences in your account profile, or opting out of promotional emails through an unsubscribe link or by emailing us at info@jadetrack.com.

Service Providers

We may provide your Personal Information to other businesses (“Service Providers”) to provide services to us or on our behalf. Categories of service providers we use include:

  • Fulfillment and account servicing vendors, which help us provide products, services and information to you, service your account or benefits, and collect past due balances;
  • Payment processors, which help us to accept and process the payments for our products/services to you;
  • Marketing and communications vendors, which help us market our products/services to you, conduct promotions, surveys, and other outreach campaigns;
  • Research and development vendors, which help us develop and improve our products and services;
  • Consumer reporting agencies, which help us evaluate your eligibility for certain products or financing options;
  • Data and business analytics vendors, which help us collect, analyze, and improve the accuracy of our data (including Personal Information);
  • IT and network administration vendors, which provide services such as data storage and management, website hosting, and data security;
  • Professional service firms, which provide accounting, legal, auditing, and other professional services; and
  • General service providers, which help us with day-to-day business operations such as office support services, courier services, facilities management, and document destruction.

In the past twelve months we may have disclosed each category of Personal Information that we collect (listed above) to Service Providers.

Third-Party Selling and Sharing

We may sell or share (for targeted advertising purposes) your Personal Information with other companies who do not provide services to us (“Third Parties”), including affiliates, advertising, social media, and analytics companies, data brokers, and other companies that sell consumer products or services. These companies may use your Personal Information for their everyday business purposes, including marketing, customer service, fulfillment, and related purposes. In the past twelve months we sold and shared Personal Information as follows:

Other Third-Party Disclosures

We may occasionally disclose your Personal Information to Third Parties, for purposes such as:

  • To comply with the law;
  • To respond to legal requests (including court orders, investigative demands and subpoenas) if, in our discretion, we believe it is necessary or appropriate;
  • To prevent or stop any illegal, unethical, or legally actionable activity;
  • To protect the safety, property, or rights of ourselves, consumers, or any other third party;
  • In connection with a proposed or actual merger, acquisition, sale, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or similar corporate transaction; 
  • To businesses controlling, controlled by, or under common control with us; and
  • For additional purposes with your consent where such consent is required by law.

In the past twelve months, we did not disclose any Personal Information to any third party (excluding service providers).

Links and Other Websites

Our Sites may contain links to third party websites, including social media platforms. Please be aware that if you access these links, you will be leaving our Site. We encourage users to read the privacy policies of those sites, as we are not responsible for their content, links, or privacy procedures.

Data Security

We recognize the importance of safeguarding the confidentiality of Personal Information from loss, misuse, or alteration. Accordingly, we employ (without obligation) commercially reasonable administrative, technical, and physical safeguards to protect Personal Information from unauthorized access, disclosure, and use.  Even with data security safeguards in place, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted on or through our Sites or Services, you do so at your own risk.

Children’s Privacy

Our Sites are not intended for children or minors (under 18 years of age). No one under age 18 should provide Personal Information to us or on the Sites. We do not knowingly collect, sell, share, or disclose Personal Information from children or minors. If you are under 18, do not use or provide any information on our Sites. If we learn we have collected or received Personal Information from a child or minor without applicable consent, we will delete that information. If you believe we might have any information from or about a child or minor, please contact us using the contact information listed below.

Additional State Privacy Rights

If you are a resident of California, Colorado, Connecticut, Maryland, New Jersey, Utah, or Virginia, you may have additional rights to access and control your Personal Information. Exemptions may apply. Consumer privacy rights for residents of these states include:

  • Opt-Out from the Sale or Sharing of Personal Information: You may have the right to direct us not to sell or share (for targeted advertising purposes) your Personal Information to Third Parties. Our Sites also recognize and process Global Privacy Control (GPC) signals (an internet function designed to allow users to automatically communicate to provide their privacy preferences). If we are able to reasonably associate a GPC signal with information we have on an identifiable consumer, we will opt that consumer out of the selling or sharing (for targeted advertising) of that consumer’s Personal Information. If we cannot reasonably associate a GPC signal with an identifiable consumer, the opt-out will be limited to only the Personal Information collected while the signal is present.
  • Right to Know: You may have the right to request twice per 12-month period that we provide you (i) the categories or specific pieces of Personal Information we collected about you; (ii) the categories of sources from which we collected your Personal Information; (iii) the business or commercial purpose for which we collected your Personal Information; and  (iv) the categories of Third Parties with whom we sold, shared, or disclosed your Personal Information, including the categories of Personal Information sold, share, or disclosed to each and the purposes for doing so. We are not permitted to provide access to specific pieces of Personal Information that creates a high risk of potential harm from disclosure to an unauthorized person.
  • Right to Delete: You may have the right to request that we delete any Personal Information we have collected about you. Exemptions may apply such as if we need the information to complete a requested or reasonably anticipated transaction, prevent security incidents or fraud, enable internal uses that are reasonably aligned with your expectations, or comply with legal obligations. We will retain a copy of your deletion request for at least two years as required by law.
  • Right to Correct: You may have the right to request that we correct inaccurate Personal Information we maintain about you. After you request to correct inaccurate Personal Information, we will provide instructions for you to provide us with optional documentation to support your request. We may decline to correct your Personal Information if a legal exemption applies such as if we determine that your request is fraudulent or abusive or if we determine, based on the totality of the circumstances, that your correction is more likely inaccurate than accurate. We may decide to delete your allegedly inaccurate Personal Information instead of correcting it. If you only wish to update your contact information or other Personal Information rather than disputing its accuracy, please make the changes directly in your account.
  • Right to Appeal: You may have the right to appeal our decision to deny, in full or in part, one or more of your privacy requests. If we deny your appeal, we will provide you with a written explanation of the reasons for our decision. If you are not satisfied with our explanation for the denial of your appeal, you may have an additional right under certain laws to contact your state Attorney General to submit a complaint about the appeal results. In such case, we will provide you with instructions for doing so

Submitting a Request

If you are a resident of a state that provides privacy rights (listed above) and would like to exercise your rights, you may submit a request emailing us at info@jadetrack.com, or through our online privacy request form. We will respond to your request as soon as possible, but no longer than what is required by applicable law. To prevent unauthorized individuals from making deletion requests, you must provide required information and/or documentation to verify your identity. Further, if you have exercised your rights and wish to submit an appeal, please email us at info@jadetrack.com.

Authorized Agent

If you are an authorized agent submitting a request for another consumer, you must provide a copy of a lawful power of attorney or written authorization from the consumer (along with proof of your identity). You will be provided options on how to provide this documentation after submitting the request. For certain types of requests, we may contact the consumer on whose behalf you claim to act to verify your authorization.

Non-Discrimination Notice

We will not discriminate against any consumer for exercising their privacy rights under law or this Privacy Policy.

California “Do Not Track” Disclosure

Do Not Track is a web browser privacy preference that causes the web browser to broadcast a signal to websites requesting that a user’s activity not be tracked. Currently, our Sites and Services do not respond to “do not track” signals.

Contact Us

To ask questions or comment about this privacy policy and our privacy practices, please email us at info@jadetrack.com or contact us using one of the options on our Contact Us page.