OUR PRIVACY SUMMARY
At Rolling Energy Resources, we are connecting electric vehicle owners to the electric utilities that provide their fuel. Everyone is in this together – utilities need to ensure that their substations and transformers can meet the new demands from vehicle charging, vehicle owners should have insight into their charging costs, and both should be empowered with tools to control their costs and to share the grid together. Everything that our company does is in service to those goals, which ultimately serve to keep rates lower and enable better decision-making for vehicle owners and utilities.
To that end, we will use your data to research charging patterns and plan for infrastructure to support customer charging, but we will never sell your data for direct marketing. If you are enrolled in a utility research, rewards, or load shifting program, we will only maintain data that identifies you for the duration of the program you signed up for. We will use your data after that to get better at what we do – identifying needs for utilities and bridging the knowledge gap – but we will anonymize it such that it contains no information that could reasonably be linked back to you personally.
1. COLLECTION OF PERSONAL INFORMATION
1.1. Personal Information. The following are categories (with non-exhaustive examples) of personal information we may collect about you and for each category the purpose for which it may be used:
|A. Individual Identifiers and Demographic Information||A real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name.|
|B. Geolocation Data||Precise physical location while charging.|
|C. Internet or Network Activity||Browsing history, search history, information on an individual’s interaction with a website, application, or advertisement.|
|D. Energy Usage Information||Energy usage information from your vehicle.|
|E. Inferences Drawn from Personal Information||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.|
Personal information does not include:
- Publicly Available Data – Publicly available information from government records.
- Deidentified or Aggregate Information – “Deidentified Information” means information that cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular individual, and for which RER has implemented technical safeguards and business processes that prohibit reidentification of the individual. “Aggregate Information” means information that relates to a group or category of individuals, from which individual identities have been removed, that is not linked or reasonably linkable to any individual or household, including via a device.
1.2. Sources of Personal Information. We obtain the categories of personal information listed above on or through our Platform from the following categories of sources:
- Personal Information You Provide. RER collects personal information when you voluntarily submit it to us. For example, we may collect or receive personal information from you when you create an account; edit registration information; sign up to receive promotional communications; use or access a Service or content available through the Platform; participate in one of our promotional sweepstakes, contests, or surveys; post a review; submit a request to our customer service team; interact with our social media pages; or otherwise interact with us or other Users through the Platform.
- Automatically Collected Personal Information. In addition to personal information that we may receive directly from you, RER indirectly collects other information from you automatically through the Platform. For example, we receive personal information from Users when a User visits and navigates our Platform on any device; installs and uses the Application; enables location-based features on the Application. We may also collect personal information about Users over time and across different websites, apps, and devices when a User accesses the Platform. Third parties also collect personal information this way on our Platform. RER collects some personal information automatically using cookies or other online tracking technologies.
- Personal Information from Your Vehicle: We may receive and store information directly from your vehicle, including vehicle make and model, battery charge, location, and odometer readings. For example, we may calculate your cost per mile driven by collecting charge times, battery percent, and odometer readings.
- Personal Information Obtained from Third Parties. In addition to the personal information that we collect from you directly and automatically, RER may receive personal information about you from other third party sources. For example, we receive personal information from your Utility Provider, our business partners, social media sites, or companies that provide personal information to supplement what we already know about Users.. We may merge or combine such personal information with the personal information we collect from you directly or automatically.
2. USE OF PERSONAL INFORMATION
RER’s primary purpose in collecting personal information is to provide the Services that you request on the Platform. RER may also use personal information for various purposes, including without limitation to:
- To Provide Our Services. We use your vehicle’s charging data to provide monthly reports to help you understand your charging patterns, and to understand infrastructure needs to support charging. If you opt-in to a time of use assistance program or demand response program with your utility, we may use your vehicles charging data to delay charging. We use your vehicles miles calculate how many miles you need per day, as well as fuel costs per mile.
- To Improve Our Services and Platform. We use personal information to understand and analyze the usage trends and preferences of our Users to make our Platform, Services, and Content better, diagnose technical issues, prevent fraud, and develop new features and functionality.
- To Understand Your Interests. We use your personal information to personalize your experience on the Platform and to deliver information about our Services relevant to your interests.
- To Respond to Your Requests or Questions. We use personal information to provide you with support and to respond to your requests for customer support, including to investigate and address your concerns and monitor and improve our responses. This may also include responding to your feedback.
- To Determine Your Eligibility and Set Up Your Account. We use your personal information to verify your identity or determine your eligibility for some of our Services, and promotions. For example, this may include verifying your age, and utility provider. If you set up an account on the Platform, we will use the registration information you provide in relation to that account creation to create, maintain, customize, and secure your account.
- To Secure the Platform. We use personal information to maintain the safety, security, and integrity of our Platform and Services, databases and other technology assets, business, and other Users.
- As Required by Law. We use personal information to respond to requests from law enforcement and as required by applicable law, court order, or government investigation.
We may create non-personal Deidentified Information or Aggregate Information from the information we collect, as permitted by law. We may use that data for our own purposes or disclose it in a non-personally identifiable manner to:
- Organizations and government entities that conduct research into energy usage or smart-grid technologies;
- Other Users of the Services for purposes of comparing energy usage to the broader community;
- Advertisers and third parties for their marketing and promotional purposes; or
- Other interested third parties.
3. SHARING OF PERSONAL INFORMATION
3.2. Related Companies and M&A Transactions. We may share your personal information with companies that are affiliated with us (that is, that control, are controlled by, or are under common control with us). In addition, if we sell all or part of its business or make a sale or transfer of assets or is otherwise involved in a merger or business transfer, we may transfer your personal information to a third party as part of that transaction, including at the negotiation stage.
3.4. Legal Compliance. We may disclose personal information in response to subpoenas, warrants, or court orders, in connection with any legal process, or to comply with relevant laws. We may also share your personal information in order to establish or exercise our rights; to defend against a legal claim; to investigate, prevent, or take action regarding possible illegal activities or fraud; to protect the safety and security of other Users; or to prevent a violation of our Terms of Service.
3.6. Behavioral-Based Advertising. We may participate in behavioral-based advertising. This means that a third party may use technology (e.g., a cookie) to collect information about your use of our Platform so that we can provide advertising about products and services tailored to your interest. That advertising may appear either on our Platform, or on other websites.
3.7. Partner or Client Offerings. We may jointly offer events, promotions, or any other product or service offerings with third party partners or our clients, which may be your employer. The personal information that you submit through an event, promotion, or other product or service offering may be combined and transmitted with the registration information related to your account. Third party partners or clients may collect information directly from you, which may be combined with personal information disclosed by us. If you decide to request, enter into, or participate in an event, promotion, or other product or service offering that is offered by us and identified as a joint effort with a third-party partner or client, the information that you provide may be shared with us and with that identified third party.
3.8. Social Networking. The Platform may offer you the ability to share your personal information through a social networking website (e.g., Facebook, Twitter), using such site’s integrated tools (e.g., Facebook “Like” button, or Twitter “Tweet” button). The use of such integrated tools enables you to share personal information about yourself with other individuals or the public, depending on the settings that you have established with such social networking site. For more information about the purpose and scope of data collection and use in connection with such social networking site or a site’s integrated tools, please visit the privacy policies of the entities that provide these social networking sites.
3.9. Public Forum and Messaging. The Platform may provide you with the opportunity to post comments, messages, or reviews in a public forum. If you decide to submit personal information at these locations, that information will be available to other Users of the Platform.
3.10. Referrals. Users may recommend other Users to join the Platform by providing their contact information or selecting friends from a social networking site. Users may also provide information about other Users of the Platform such as reviews of the Services or products that he or she received, booking or scheduling information, or reference information.
4. SECURITY OF PERSONAL INFORMATION
No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from the risks presented by unauthorized access or acquisition, including encrypting your passwords, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any unauthorized access or acquisition of your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
5. YOUR CHOICES
You can make the following choices regarding your personal information:
5.1. Access to Your Personal Information. You may request access to your personal information by contacting us as described below. We will grant you reasonable access to the data that we have about you as required by law.
5.2. Changes to Your Personal Information. We rely on you to update and correct the personal information contained in your Account. Note that we may keep historical information in our backup files as permitted by law. If our Platform does not permit you to update or correct certain personal information, please contact us as described below.
6. OPTING OUT
You can make the following choices to opt out of certain activities regarding your personal information:
6.1. Promotional E-mails. You may choose to provide us with your e-mail address for the purpose of allowing us to send newsletters, surveys, offers, and other promotional materials related to our Platform, as well as targeted offers from third parties. You can stop receiving promotional e-mails by clicking the “unsubscribe” links in the e-mails or by contacting us as described below. If you decide not to receive promotional e-mails, we may still send you service-related communications, such as those about your Account, to fulfill orders for products and service you have requested, or deliver notifications directly to you through the Platform.
6.2. Behavioral-Based Advertising. We participate in behavioral-based advertising. This means that a third party may use technology (e.g., a cookie) to collect information about your use of our Platform so that we can provide advertising about products and services tailored to your interest. That advertising may appear either on our Platform, or on other websites. If you wish to limit third parties’ collection of information about your use of our Platform, you can opt-out of such at the Digital Advertising Alliance in the US, the Digital Advertising Alliance of Canada in Canada, or the European Digital Advertising Alliance in Europe. PLEASE NOTE THAT OPTING-OUT OF BEHAVIORAL ADVERTISING DOES NOT MEAN THAT YOU WILL NOT RECEIVE ADVERTISING WHILE USING THE PLATFORM. IT WILL, HOWEVER, EXCLUDE YOU FROM INTEREST-BASED ADVERTISING CONDUCTED THROUGH PARTICIPATING NETWORKS, AS PROVIDED BY THEIR POLICIES AND CHOICE MECHANISMS.
6.3. Do-Not-Track. Some web browsers and devices permit you to broadcast a preference that you not be “tracked” online. At this time, we do not modify your experience based upon whether such a signal is broadcast.
7. RESIDENTS OF CALIFORNIA
The following applies to residents of California.
7.1. Notice to California Residents. RER must disclose whether the following categories of personal information are disclosed for a “business purpose” or “valuable consideration” as those terms are defined under California law. Note that while a category below may be marked, that does not necessarily mean that we have personal information in that category about you. In the preceding twelve months, we have disclosed the following categories of Personal Information in the manner described.
|Category||Personal Information is Disclosed for a Business Purpose||Personal Information is Disclosed for Valuable Consideration|
|Individual Identifiers and Demographic Information||Yes||No|
|Internet or Network Activity||Yes||No|
|Energy Usage Information||Yes||No|
|Inferences Drawn from Personal Information||Yes||No|
7.2. Notice of Disclosure for Direct Marketing. Under California Civil Code sections 1798.83-1798.84, California residents who have an established business relationship with RER are entitled to ask us for a notice describing what categories of personal information we share with third parties for their direct marketing purposes. This notice will identify the categories of information shared with and will include a list of the third parties with which it is shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit your request to the address listed in the section titled “CONTACTING US” below.
8. EXERCISING YOUR PRIVACY RIGHTS
8.1. No Fee Usually Required. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive.
8.2. What We May Need from You. When exercising your rights or otherwise assisting you, we may need to request specific information from you to help us confirm your identity. This is a security measure to ensure we do not disclose personal information to any person who is not entitled to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
8.3. Time to Respond. We try to respond to all legitimate requests within 30 days of your request. Occasionally it may take us longer than 30 days to respond, for instance if your request is particularly complex or you have made a number of requests. In this case, we will notify you of the delay, and may continue to update you regarding the progress of our response.
8.4. No Discrimination. You will not be subject to discrimination as a result of exercising the rights described herein. In some cases, when you exercise one of your rights, we will be unable to comply with the request due to legal obligations or otherwise, or we will be unable to provide you certain Services. These responses are not discrimination and our reasons for declining your request or ceasing Services will be provided at that time.
8.5. Authorized Agent. You may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s identification information, and the authorized agent’s identification information.
9. CONTACTING US
Rolling Energy Resources Inc.
Attn: Rolling Energy Privacy Agent
2500 30th Street, Suite 207
Boulder, CO 80301
Effective Date: May 19, 2020
To help operate the Site and Service, enhance your experience, and collect information about online activity, RER places small data files on your device known as “cookies”, or other similar technologies (e.g., pixel tags, web beacons, local shared objects). Cookies and similar technologies enable RER to personalize the Site, help make the Site load faster (through “load balancing” technology) and enable Customers to collect useful data with the Service. These technologies may allow RER and its Customers to store and manage your preferences and settings; measure and analyze how You use the Site and Services and effectiveness of RER communications; offer targeted products, programs, and services; and help RER improve its products, services, and security.
The table below explains the types of cookies RER uses on its websites and why they are used. Also provided are examples of the cookies set by RER, with explanations of their purpose. Please note that this is not an exhaustive list, but rather aims to be a representative summary.
Essential and Strictly Necessary
These cookies are essential for the website and services to perform their basic functions. These include those required to allow registered users to authenticate and perform account related functions, as well as to save the contents of virtual “carts” on for e-commerce functionality.
These cookies are used to store preferences set by users such as account name, language, and location.
RER use these cookies to help identify and prevent potential security risks.
Analytics and Performance
Performance cookies collect information on how visitors interact with RER websites, including what pages are visited most, as well as other analytical data. RER uses these details to improve how the websites function and to understand how visitors interact with them.
These cookies are used to display relevant advertising to users who use our services or visitors that visit websites RER provides, as well as to understand and report on the efficacy of ads served on RER websites. They track details such as the number of unique visitors, the number of times particular ads have been displayed, and the number of clicks the ads have received. They are also used to build visitor profiles, including showing You ads based on products you’ve viewed or acts You have taken on RER (and other) websites. These are set by RER and trusted third party networks and are generally persistent in nature.
Third Party / Embedded Content
Sites using RER’s Service make use of different third party applications and services to enhance the experience of website visitors. These include social media platforms such as Facebook and Twitter (through the use of sharing buttons). As a result, cookies may be set by these third parties, and used by them to track your online activity. RER has no direct control over the information that is collected by these cookies.
- Cookie settings in Internet Explorer
- Cookie settings in Firefox
- Cookie settings in Chrome
- Cookie settings in Safari web and iOS.
To find out more on how to manage and delete cookies, visit https://aboutcookies.org/. For more details on your choices regarding use of your web browsing activity for interest-based advertising You may visit the following sites:
On a mobile device, You may also be to adjust your settings to limit ad tracking.
You may see a “cookie banner” on our websites. If You are visiting one of the RER Customer’s sites from the EU, then RER does not set, or allow its ad partners to set, cookies that are used to show You targeted ads before You click to accept. When You consent in this manner, RER and its advertising partners may set advertising cookies on the site You are visiting and on other of our websites, dashboards, and services. RER will display the banner to You periodically, just in case You change your mind.
OTHER TRACKING TECHNOLOGIES
In addition to cookies, we may use web beacons, pixel tags, and other tracking technologies on the Site to help customize the Site and improve your experience. A “web beacon” or “pixel tag” is tiny object or image embedded in a web page or email. They are used to track the number of users who have visited particular pages and viewed emails, and acquire other statistical data. They collect only a limited set of data, such as a cookie number, time and date of page or email view, and a description of the page or email on which they reside. Web beacons and pixel tags cannot be declined. However, you can limit their use by controlling the cookies that interact with them.
Rolling Energy Resources Inc.
Attn: Rolling Energy Privacy Agent
2500 30th Street, suite 207
Boulder, CO 80301