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U.S. STATE PRIVACY NOTICE

This U.S. State Privacy Notice describes how Vector Technology Solutions Ltd and its affiliates (collectively, “VTS,” “our,” “we,” and “us”) collect, use, share, and protect your personal information when you visit our website or use our services, what choices you have relating to your personal information, and how you can contact us. Residents of certain U.S. States whose information is processed pursuant to applicable U.S. State law privacy requirements (collectively, “State Privacy Laws”), including the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, “CCPA”) are entitled to certain additional information and have certain additional rights, as described in this Notice.  Any terms defined in the CCPA have the same meaning when used in this Notice.  This Notice also serves as a notice at collection under the CCPA. 

1. Information We Collect

During the preceding 12 months, we have collected the following categories of personal information about consumers through our websites, directly from consumers, or from third party sources including our partners, licensees, users, service providers, and contractors:

Categories of Personal Information Collected

Identifiers (including, for example, names, email addresses, postal addresses, and IP addresses)

 

“Personal Information” as defined in California Civil Code section 1798.80, subsection (e) (such as names, address, and telephone numbers)

 

Commercial information 

Purposes for Collection

Providing our products and services and maintaining or servicing accounts

Communicating with you

Marketing and advertising our products and services

Monitoring and analyzing trends, usage, and activities relating to our websites, products, and services

Supporting our operations and improving our products, services, and websites

Meeting legal, compliance, and recordkeeping requirements

Quality assurance, auditing, security, fraud prevention, and debugging

Categories of Personal Information Collected

Internet or other electronic network activity information (such as website usage details, IP addresses, or the equipment used to access our network)

 

Geolocation data 

Purposes for Collection

Providing our products and services and maintaining or servicing accounts

 

Communicating with you

Operating our websites, including tailoring our content and your online experience

Marketing and advertising our products and services

Monitoring and analyzing trends, usage, and activities relating to our websites, products, and services

Supporting our operations and improving our products, services, and websites

Meeting legal, compliance, and recordkeeping requirements

Quality assurance, auditing, security, fraud prevention, and debugging

Categories of Personal Information Collected

Inferences drawn from any of the information identified above to create a profile about a consumer reflecting, for example, the consumer’s preferences, characteristics, or predispositions 

Purposes for Collection

Providing our products and services and maintaining or servicing accounts

Monitoring and analyzing trends, usage, and activities relating to our websites, products, and services

Quality assurance, auditing, security, fraud prevention, and debugging

Categories of Personal Information Collected

Sensitive personal information, such as precise geolocation

Purposes for Collection

Providing our products and services and maintaining or servicing accounts as reasonably expected by an average consumer

 

Quality assurance, auditing, security, fraud prevention, and debugging

2. How We Collect Information

We collect and process your Personal Information when you interact with us and our websites, when you use or access our or our partners’, licensees’, or users’ equipment, products, or services. We may also collect information about you from partners who may receive this data when you visit or use their services and products or through the third parties they work with.  For example, your energy provider may provide us with your metering information to the extent necessary for us to perform software-based measurement and related services for the energy provider. We also use automatic data collection technologies, including those of service providers and third parties, to collect additional information about your equipment, browsing actions, and patterns including details of your visits to our websites, information about your computer and Internet connection, and information about your online activities over time and across third-party websites. 

3. How Long We Keep Information

We keep the categories of Personal Information described above for as long as necessary for the purposes described in this Privacy Notice or otherwise authorized by law.  To determine the appropriate retention period for personal information, we will consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data, the purposes for which we collect and process the personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.  Where information is used for more than one purpose, we will retain it until the purpose with the latest period expires. 

4. Information We Disclose

We do not sell or share your Personal Information for monetary or other valuable consideration.  But we may disclose, and in the preceding 12 months have disclosed, each of the categories of Personal Information we collect to third parties and vendors or other service providers for the following business purposes:

Category of Personal Information Disclosed

Identifiers (including, for example, names, email addresses, postal addresses, and IP addresses)

 

“Personal Information” as defined in California Civil Code section 1798.80, subsection (e) (such as names, address, and telephone numbers)

 

Commercial information 

Category of Party to Whom Information Was Disclosed for a Given Business Purpose

Corporate affiliates to provide our products and services; government entities for compliance and legal purposes; email service providers for content delivery services, communication, and customer support; server/hosting service providers for web-hosting and data security services; internet service providers to operate our Website; help-desk service providers for customer-support services

Category of Personal Information Disclosed

Professional information (including information relating to your role as a representative or agent of a company, such as your work title and contact information)

Category of Party to Whom Information Was Disclosed for a Given Business Purpose

Corporate affiliates to provide our products and services; government entities for compliance and legal purposes; email service providers for content delivery services, communication, and customer support; server/hosting service providers for web-hosting and data security services; help-desk service providers for customer-support services

Category of Personal Information Disclosed

Internet or other electronic network activity information (such as website usage details, IP addresses, or the equipment used to access our network)

 

Non-precise geolocation data 

Category of Party to Whom Information Was Disclosed for a Given Business Purpose

Server/hosting service providers for web-hosting and data security services; internet service providers to operate our Website; productivity software service providers to enhance our products and services; help-desk service providers for customer-support services

Category of Personal Information Disclosed

Inferences drawn from any of the information identified above to create a profile about a consumer reflecting, for example, the consumer’s preferences, characteristics, or predispositions 

Category of Party to Whom Information Was Disclosed for a Given Business Purpose

Website hosting service providers to analyze Website usage and improve services

5. Sensitive Personal Information

Other than the use or disclosure of Sensitive Personal Information to perform the services or provide the goods reasonably expected by an average consumer who requests such goods or services, to perform the services set forth in California Civil Code § 1798.140(e)(2), (4), (5), or (8), or as otherwise authorized by regulations adopted pursuant to Civil Code § 1798.185(a)(19)(C), we do not use or disclose sensitive personal information. 

6. Children’s Privacy Online

Our services are not directed to children under 18 years of age.  VTS does not knowingly collect any personal information of children under 18 years of age unless required by applicable law.  VTS does not knowingly sell or share the personal information of children under 18 years of age.

7. Your Privacy Rights

Certain U.S. state privacy laws provide residents of those states with specific rights regarding their Personal Information.  This section describes your rights under those laws and explains how to exercise those rights.  An authorized agent may also submit requests asserting those rights on your behalf, subject to verification.  We will never discriminate against you for exercising your rights, including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the U.S. state privacy laws that apply to you.

 

To make such a request, you or an authorized agent may submit the privacy request form at https://www.vts.energy/privacy or email us at privacy@vts.energy

 

In order to verify that you are the consumer to whom the personal information relates, we may request certain information from you.  To obtain information about categories of personal information, we may request that you submit two data points that match data points that we maintain about you and that we determine are reliable for purposes of verifying your identity.  To obtain specific pieces of information we may have about you, we may request that you submit at least three pieces of personal information that we can match to information we maintain along with a signed declaration under penalty of perjury.  The type of verification we may require for a request to access, delete or correct your Personal Information will depend on the nature of the information that you seek to access, delete or correct. 

Right to know and access personal information

You have the right to request that we disclose what personal information VTS collects about you.  For example, California residents may request that we disclose:

 

  • The categories of personal information;

  • The categories of sources from which your information is collected;

  • The business or commercial purpose for collecting, selling or sharing your information;

  • The categories of third parties to whom we may disclose personal information; and  

  • The specific pieces of information that we have collected about you. 

 

You also have the right to request, to the extent technically feasible, a portable set of your personal information.

Right to request deletion of your personal information

You have the right to request that VTS deletes the personal information it has about you subject to certain limitations.  If we do not delete your personal information for reasons permitted under applicable law, we will let you know.

Right to correct inaccurate personal information

You have the right to request that VTS corrects inaccurate personal information that we maintain about you.

8. Changes to This Privacy Notice

This Privacy Notice was last updated on 31 July 2025.  We may change this Notice from time to time and we will tell you about a change in the Notice by posting an updated Notice on our website.  If you have any questions or concerns about this Privacy Notice or VTS’s information practices, you can contact us at the following email address:  privacy@vts.energy

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