Privacy Policy

Forefront Power, LLC and Forefront Power Development LLC (collectively, “ForeFront Power,” “we,” “our,” or “us”) are committed to protecting your privacy. This Privacy Policy explains how your personal information is collected, used and disclosed by ForeFront Power. This Privacy Policy applies to our website (forefrontpower.com) (our “Site”), and our products and services (collectively with the Site, our “Service”). By accessing or using our Service, you signify that you have read, understood and agree to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy.

1. WHAT INFORMATION DO WE COLLECT AND FOR WHAT PURPOSE?

The categories of information we collect can include:

• Information you provide to us directly. We may collect personal information, which includes but is not limited to, sensitive information, such as your first and last name, company name, address, credentials to your online utility accounts, information related to your utility usage and utility bills, precise geolocation, phone number, social security number, education, employment, employment history, medical or health information, criminal or credit report background information, race or ethnic origin, credit information (such as FICO scores), and e-mail address when you register for our Service, use our Service as integrated in or used in conjunction with one of our partners’ goods or services, sign up for our mailing list, apply for jobs, or otherwise communicate with us. We may also collect any communications between you and ForeFront Power and any other information you provide to ForeFront Power.
• Information we receive from third party sites you connect, or allow to connect, to our Service. We may receive personal information about you from third parties and combine that with information we collect through our Service. For example, when you interact with us through a social media site or third party service, such as when you like, follow or share ForeFront Power content on Facebook, LinkedIn, Twitter, Pinterest, Instagram or other sites, we may receive information from the social network including your profile information, picture, user ID associated with your social media account, and any other information you permit the social network to share with third parties. The data we receive from these third-party sites or other sources is dependent upon that third party’s policies and your privacy settings on that third-party site. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our website or Service.
• Information we receive from third parties. From time to time, we may receive information about you from third parties, such as companies that we have partnered with to provide our Services to their customers. We may also collect information about you that is publicly available.

We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages or direct mail. We may also send you Service-related emails or messages (e.g., account verification, change or updates to features of the Service, technical and security notices). For more information about your communication preferences, see “Control Over Your Information” below.

2. HOW WE USE COOKIES AND OTHER TRACKING TECHNOLOGY TO COLLECT INFORMATION.

Like most websites and online services, we and our third-party partners automatically collect certain types of usage information when you visit our Services, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, web beacons, and similar technology (collectively, “tracking technologies”). These tracking technologies collect information about how you use the Service (e.g., the pages you view, the links you click, and other actions you take on the Service), information about your browser and online usage patterns (e.g., IP address, browser type, browser language, referring / exit pages and URLs, pages viewed, whether you opened an email, links clicked), and information about the device(s) you use to access the Service (e.g., mobile device identifier, mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, and depending on your mobile device settings, your geographical location data (which could include GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device), or we may be able to approximate a device’s location by analyzing other information, like an IP address. We, or our third-party partners, may link your various devices so that content you see on one device can result in relevant advertising and content displayed on another device, and so that we may recognize and contact you on the various devices you may use. We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Service. Although we do our best to honor the privacy preferences of our Service visitors, we are not able to respond to Do Not Track signals from your browser at this time. We may collect analytics data, or use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners, and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.

We use or may use the data collected through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) recognize and contact you across multiple devices; (d) provide and monitor the effectiveness of our Service; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our Service.

If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the Service, as some features and services on our Service may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it.

Cross-Device Linking: We, or our third-party partners, may link your various devices so that content you see on one device can result in relevant advertising on another device. We do this by collecting information about each device you use when you are logged in to our Service. We may also work with third party partners who employ tracking technologies, or the application of statistical modeling tools, to determine if two or more devices are linked to a single user or household. We may share a common account identifier (such as an email address or user ID) with third party advertising partners to help recognize you across devices. We, and our partners, can use this cross-device linkage to serve interest-based advertising and other personalized content to you across your devices, to perform analytics and to measure the performance of our advertising campaigns.

3. SHARING OF YOUR INFORMATION

We may share your personal information in the instances described below. For further information on your choices regarding your information, see the “Control Over Your Information” section below.

We may share your personal information with:

• Third parties at your request.
• Our subsidiaries and affiliates.
• With third parties who may have products or services we think you may enjoy;
• Third-party vendors and other service providers that perform services on our behalf, as needed to carry out their work for us, which may include identifying and serving targeted advertisements, providing mailing services, providing tax, accounting, and legal services, web hosting, or providing analytic services;
• Other parties in connection with a company transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party, or in the event of a bankruptcy or related or similar proceedings; and
• Third parties as required by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of ForeFront Power, our visitors, or others.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of ForeFront Power, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
• For any other purpose disclosed by us when you provide the information.

We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.

4. CONTROL OVER YOUR INFORMATION

How to control your communications preferences: You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Service, technical and security notices).

5. HOW WE STORE AND PROTECT YOUR INFORMATION

Data storage and transfer: Your information collected through our website may be stored and processed in the United States or any other country in which ForeFront Power or its affiliates or service providers maintain facilities. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. or any other country in which ForeFront Power or its parent, subsidiaries, affiliates, or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

Keeping your information safe: We care about the security of your information and employ physical, administrative, and technological safeguards designed to preserve the integrity and security of personal information collected through our website. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

6. LINKS TO OTHER WEB SITES AND SERVICES

The Services may contain links to and from third-party websites of our business partners, advertisers, and social media sites and our users may post links to third-party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies (including how they manage their policies) and that we do not accept any responsibility or liability for their policies. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the websites of third party sites.

7. REGION-SPECIFIC RIGHTS

Nevada Residents. Under Nevada law, Nevada residents may opt out of the “sale” of their personal information, where the information is exchanged for monetary consideration.  If you are a Nevada resident, you may submit a request to opt out of potential future sales under Nevada law by sending a message to our team at privacy@forefrontpower.com.  Please note we will take reasonable steps to verify your identity and the authenticity of the request.

California Residents. California law requires us to provide certain information regarding the categories of personal information we collect from California residents. For purposes of this section, “personal information” has the meaning provided by the California Consumer Privacy Act, as amended by the California Privacy Rights Act (the “CCPA”) and does not include information that cannot be verified, is publicly available, that is deidentified or aggregated such that it is not capable of being associated with us, or that is excluded from the CCPA’s scope, such as personal information covered by certain sector-specific privacy laws, such as the HIPAA, the FCRA, GLBA or the Driver’s Privacy Protection Act of 1994 or information collected from our business partners.

Since January 1, 2022, we have collected the following categories of personal information from California residents:

• Identifiers, such as your name, address, phone number, email address, date of birth, or other similar identifiers;
• Internet/Network information, such as device information, logs and analytics data;
• Geolocation data, such as location data generated based on your IP address;
• Inferences about your interests and preferences, generated from your use of our sites;
• Other personal information you choose to provide us through our online forms or other means of communication.

We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages or direct mail.Please see the section above titled “Sharing Of Your Information” for a detailed description of the categories of third parties we might share personal information with.

If you are a resident of California, you have the following rights in respect to your personal information that we hold, subject to certain exceptions (including if complying with your request would restrict our ability to comply with laws or an investigation or to exercise or defend legal claims):

• The Right to Know.  The right to have us disclose to you any or all of the following information relating to your personal information we have collected and disclosed any time after January 1, 2022, upon verification of your identity:
  • The specific pieces of personal information we have collected about you;
  • The categories of personal information we have collected about you;
  • The categories of sources of the personal information;
  • The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
  • The categories of personal information we have sold and the categories of third parties to whom the information was sold; and
  • The business or commercial purposes for collecting or selling the personal information.
• Verification.  In verifying your identity, we will not disclose the following in response to a CCPA request to exercise an access right: an individual’s Social Security number, driver’s license number, or other government-issued identification number, financial account number, health insurance or medical identification number, or account password, security questions and answers, or unique biometric data generated from measurements or technical analysis of human characteristics.  Instead, we will inform the individual with sufficient particularity that it has collected such type of information.
• The Right to Request Correction or Deletion.  The right to request a correction to or the deletion of personal information we have collected from you.
• The Right to Opt Out of Personal Information Sales or Sharing.  ForeFront Power does not currently “sell” personal information about our customers as most people would typically understand that term.  However, we do allow certain third-party advertising partners to collect information about the users of our Services for the purposes of serving ads that are more relevant on other platforms.  To the extent this practice is interpreted to constitute a “sale” or “sharing” under the CCPA, please see our “Do Not Sell My Personal Information” page for more information about the use of cookies on our Site and your choices with respect to sharing information with these third-parties.
• The Right to Opt In of Personal Information Sales or Sharing.  California residents who are under the age of 16 are required to provide consent to opt in of any sharing of personal information.  Please see our “[Opt In Consent]” page to submit an opt in request if you are a California resident under the age of 16.
• Shine The Light.  California Civil Code Section 1798.83 permits you to request information regarding the disclosure of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. You may make one request each year by contacting us at https://www.forefrontpower.com/privacy/#contact.

You also have the right to be free of retaliation and discrimination for exercising these rights. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.

You may submit a request to exercise your rights through one of the mechanisms described below. We will need to verify your identity before processing your request, which may require us to request additional personal information from you.  In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our systems, or as permitted by law.

• To exercise your Right to Know, please contact us using the contact details below or by emailing us at privacy@forefrontpower.com.
• To exercise your Right to Request Correction or Deletion, please contact us using the contact details below or by emailing us at privacy@forefrontpower.com.
• To exercise your Right to Opt Out of Personal Information “Sales” or “Sharing”, please click the following link:

Do Not Sell My Personal Information

Authorized Agents

If you want to make a request as an authorized agent on behalf of a California resident, you may use the submission methods noted above.  As part of our verification process, we may request that you provide, as applicable, proof concerning your status as an authorized agent, which also may include:

• Proof of your registration with the California Secretary of State to conduct business in California; and/or

• A power of attorney from the California resident pursuant to Probate Code sections 4121-4130.

If you are making a request on behalf of a California resident and have not provided us with a power of attorney from the resident pursuant to Probate Code sections 4121-4130, we may also require the resident to:

• Verify the resident’s own identity directly with us; or

• Directly confirm with us that the resident provided you permission to submit the request.

8. HOW TO CONTACT US

If you have any questions about this Privacy Policy or the website, please contact us at https://www.forefrontpower.com/privacy/#contact.

9. CHANGES TO OUR PRIVACY POLICY

We may modify or update this Privacy Policy from time to time to reflect the changes in applicable law and/or in our business and practices, and so you should review this page periodically. When we change the Privacy Policy in a material manner we will let you know and update the ‘last modified’ date at the bottom of this page. If you object to any changes, you may close your account. Continuing to use our Services after we publish changes to this Privacy Policy means that you are consenting to the changes.

This Privacy Policy was last modified on December 30, 2022.