Last updated August 15, 2023

Enel X Way USA Privacy Policy

California residents privacy statement

Notice at Collection for California Residents

This Privacy Policy applies to Enel X Way USA, LLC, (“Enel X Way”, “we”, “us,” “our,” and "Company").

 

Enel X Way is committed to ensuring the privacy of your personal information. We are further committed to preventing unauthorized access to that information. Our Privacy Policy details what personal information is collected from our members, participants, users, business representatives, and others and explains how we use it, how it is stored, and your choices related to our use of your information.

 

WHO WE ARE

Enel X Way is a global innovator of smart value-added services and solutions that enables businesses and communities to create, store, use, and manage energy more efficiently, sustainably, and strategically. To achieve our mission of becoming a global producer of sustainable, innovative, and simple technology solutions, we develop custom energy strategies to enable our customers meet their energy goals.

 

We have a reputation in the market for addressing the key business problems of our clients through better energy intelligence, tackling the biggest drivers of unnecessary energy costs. We have also developed products, including smart grid electric vehicle charging solutions.

 

Enel X Way, incorporated as Enel X Way USA, LLC, is headquartered in San Carlos, California, in the United States. Enel X Way is part of a global enterprise. We operate the Enel X Way the website located at https://www.enelxway.com/us/en, web applications for business, utilities, and procurement, mobile applications, and related customer support, services and other solutions (collectively referred to as “Services”).

 

We respect your privacy and take safeguarding your data seriously. Please read this Privacy Policy to understand what Personal Information (defined below) we collect from you, how we use it, and your choices related to our use of your Personal Information. If you do not agree with this Privacy Policy, please do not use the Services.

 

WHAT IS PERSONAL INFORMATION?

"Personal Information" means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. Under specific laws, Personal Information may include any information relating to a household.

 

PERSONAL INFORMATION WE PROCESS

 

We process Personal Information that you actively submit to us, that we automatically collect through your use of our Services, and that we collect from third-party sources. We may process your Personal Information with or without automatic means, including collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction of your Personal Information. We do not sell the Personal Information we collect to other parties.

 

We process the Personal Information of data subjects that includes our customers, users, business representatives, potential clients, and others.

 

Personal Information that you actively submit to us.

We collect Personal Information that you actively submit to us through an account, mobile applications, website forms, email subscriptions, surveys, customer service, inquiries, social media, and other interactions. You will know when we collect your Personal Information through these interactions because we will directly ask you for the information. We will require certain Personal Information for you to use our Services or for us to be able to contact you. There may also be circumstances where providing Personal Information is optional and does not impact your access to Services.

 

  • Your Account. When you register an account with us, either through the website or a mobile application, we ask you to provide your name, email, and password. The mobile applications provide an alternative option to register with a Facebook or Google account, and web applications may also offer your Twitter ID or Apple ID as a login option. Additional information collected may include your phone number, address, country/nationality, and, where relevant, your credit card information for payment. Mobile applications may offer you an option to use a Face ID login.
  • Shopping. We sell a range of products online, where we collect payment information such as your billing address, credit card number and expiration date, and your shipping address for delivery.
  • Email Subscriptions. Users have an option to sign up on our website to receive news and offers through email.
  • Contact Us. We provide online forms for users to contact us on specific topics like customer support, sales questions, interest in a partnership, or expert advice. We collect your name, email address, a description of the request, and also ask for your job title and company name when relevant.
  • Support. Our online form provides support for our product sales. We collect your name, email address, country, nature of your inquiry, and allow you to upload an attachment.
  • Social Media. We invite users to join us on social media, through platforms like Twitter, Facebook, and Instagram, with links available directly from the Enel X Way website.
  • Surveys. We occasionally conduct surveys in order to gather data central to assessing our business objectives and understanding our customers and the market. Participation in surveys is always optional. Information provided in surveys is anonymized and aggregated for analysis.
  • Events. We collect your name and contact information to register you for events.

 

Personal Information we automatically collect through your use of the Services.

We receive some Personal Information automatically when you visit Enel X Way Services. This includes information about the device, browser, and operating system you use when accessing our Services, your IP address, the website that referred you, which pages you request and visit, and the date and time of each request you make.

 

Personal Information of minors.

The Services are not intended for users younger than 13 years of age. We do not actively collect or otherwise process Personal Information from users under the age of 13. If we become aware that an individual under the age of 13 has submitted Personal Information without verifiable parental consent, we will remove his or her information from our files.

 

Special Categories of information.

We do not actively collect or otherwise process special categories of personal data as identified in the EU General Data Protection Regulation (“GDPR”) including data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade-union membership, or genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. We do not actively collect or otherwise process personal data relating to criminal convictions and offences.

 

COOKIES AND SIMILAR TRACKING TECHNOLOGIES

We (and the third-party service providers working on our behalf) use various technologies to collect Personal Information. This may include saving cookies to your device. For information on what cookies are, which ones we use, why we use them, and how you can manage their use, please see our Cookie Policy at https://www.enelxway.com/us/en/cookie-policy.

 

HOW WE USE YOUR PERSONAL INFORMATION

We use your Personal Information to operate our Services, deliver products, find and book charging stations, fulfill our contractual obligations in our service contracts with customers, to review and enforce adherence to our Terms, to analyze the use of the Services in order to understand how we can improve our content and service offerings and products, and for administrative and other business purposes. We process Personal Information for our business purposes, including sales leads, subscriptions services, payments, employee training, data analysis, security monitoring, auditing, research, and to comply with applicable laws, exercise legal rights, and meet tax and other regulatory requirements.

 

In this context, the legal basis for our processing of your Personal Information is either the necessity to perform contractual and other obligations, our legitimate business interest as a provider of services, regulatory requirements, or in some instances your explicit consent.

 

SHARING OF PERSONAL INFORMATION

We may share your Personal Information in the following circumstances:

 

  • Third-party Service Providers. We may share information we collect about you with third-party service providers to perform tasks on our behalf in supporting the Services. The types of service providers, or sub-processors, to whom we entrust Personal Information include: (i) payment providers; (ii) providers of hosting services; (iii) sales and marketing providers; (iv) providers of analytic data services; and (v) other services such as system support.
  • Regulatory Bodies, Agencies, and Law Enforcement. We may access and disclose your Personal Information to regulatory bodies if we have a good-faith belief that doing so is required under applicable law or regulation. This may include submitting Personal Information required by tax authorities. We may disclose your Personal Information in response to lawful requests by public authorities or law enforcement, including to meet security or law enforcement requirements. If we are going to release your Personal Information in this instance, our policy is to provide you with notice unless we are prohibited from doing so by law or court order.
  • Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your Personal Information may be transferred as part of such a transaction as permitted by law and/or contract. Should such an event occur, Enel X Way will endeavor to direct the transferee to use Personal Information in a manner that is consistent with the Privacy Policy in effect at the time such Personal Information was collected.
  • Other Disclosures. We may also disclose your Personal Information to exercise or defend legal rights; to take precautions against liability; to protect the rights, property, or safety of the Services, of any individuals, or of the general public; to maintain and protect the security and integrity of our services or infrastructure; to protect ourselves and our services from fraudulent, abusive, or unlawful uses; or to investigate and defend ourselves against third-party claims or allegations. Disclosures may be made to courts of law, attorneys and law enforcement, or other relevant third parties in order to meet these purposes.
  • Authorized third parties.  We may share your information with authorized third parties including third-party network providers, utilities or their respective employees to help us provide our Services to you.
  • Please note that we share aggregated information and non-identifying information with third parties for industry research and analysis, demographic profiling, and other similar purposes. In addition, our Services may contain links to other websites not controlled by us, and these other websites may reference or link to our Services; we encourage you to read the privacy policies applicable to these other websites.

 

Again, we do not sell Personal Information.

 

RETENTION OF PERSONAL INFORMATION

Enel X Way retains Personal Information for a reasonable time period to fulfill the processing purposes mentioned above. Personal Information is then archived for time periods required or necessitated by law or legal considerations. When archival is no longer required, Personal Information is deleted from our records.

 

We retain your account information, including Personal Information in your profile, while your account is active. After termination or deactivation of your account, we delete your account as part of our standard delete function. If you participated in market research, your contribution becomes part of the market data is retained indefinitely, with data anonymized and aggregated.

 

We retain purchase information for a relevant time to align with warranties associated with the product. Please note we may retain information within our internal systems for backup, archival, audit, or other purposes.

 

We retain Personal Information that we are required to retain to meet our regulatory obligations including tax records and transaction history. We regularly review our retention policy to ensure compliance with our obligations under data protection laws and other regulatory requirements. We regularly audit our databases and archived information to ensure that Personal Information is only stored and archived in alignment with our retention policies.

 

PROTECTION OF PERSONAL INFORMATION

Enel X Way uses technical and organizational measures to protect the Personal Information that we store, transmit, or otherwise process, against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. We regularly consider appropriate new security technology and methods as we maintain and develop our software and systems.

 

However, you should keep in mind that the Services are run on software, hardware, and networks, any component of which may, from time to time, require maintenance or experience problems or breaches of security beyond our control. Please also be aware that despite our best efforts to ensure the security of your data, we cannot guarantee that your information will be 100% secure.

 

Please recognize that protecting your Personal Information is also your responsibility. We urge you to take every precaution to protect your information when you are on the Internet, such as using a strong password, keeping your password secret, and using two-factor authentication.

 

INTERNATIONAL DATA TRANSFER

Your Personal Information may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide your Personal Information to us, we will transfer your Personal Information to the United States and process it there. Where we transfer your Personal Information, we will take all reasonable steps to ensure that your privacy rights continue to be protected.

 

In the case of transfers of data out of Europe, we have committed to comply with EU General Data Protection Regulation ("GDPR") and implement Standard Contractual Clauses as required. We endeavor to utilize third-party service providers from the United States that provide adequate protections that are compliant with the GDPR such as implementing Standard Contractual Clauses or Binding Corporate Rules.

 

OUR COMMITMENT TO THE PRIVACY SHIELD

Enel X Way complies with the GDPR regarding the collection, use, and retention of Personal Information transferred from the EEA and UK to the United States. If there is any conflict between the terms in this Privacy Policy and the GDPR, the GDPR shall govern.

 

If you have not received a timely or satisfactory response to your question or complaint, please contact one of the independent recourse mechanisms listed below:

 

EU Data Protection Authorities (“DPAs”)

 

Please note that this independent dispute resolution body is designated to address complaints and provide appropriate recourse free of charge to the individual.

 

PRIVACY RIGHTS

In compliance with the GDPR, individuals have the right to access Personal Information and to correct, amend, restrict, or delete that information where it is inaccurate, or has been processed in violation of GDPR, except where the burden or expense of providing access is disproportionate to the risks to the individual's privacy in the case in questions, or where the rights of persons other than the individual will be violated.

 

If you have an Enel X Way account, we rely upon you to keep your information up to date. You may edit your profile information at any time through your account settings. For email subscriptions, you may opt-out at any time by selecting the “Unsubscribe” link at the end of the email communication. Similarly, for email communication of a marketing nature, we provide the ability for you to unsubscribe directly from the email.

 

If you demonstrate the inaccuracy or incompleteness of Personal Information, Enel X Way will amend the information as required. If appropriate, we will send the amended information to service providers to whom the information has been disclosed.

 

Where we rely upon consent as a legal basis for processing, you may withdraw your consent at any time. Please note the withdrawal of your consent does not affect the lawfulness of processing based on consent before withdrawal.

 

Individuals in the EEA, UK, and Switzerland have certain rights that may be subject to limitations and/or restrictions. These rights include the right to: (i) request access to and rectification or erasure of their Personal Information; (ii) obtain restriction of processing or to object to processing of their Personal Information; and (iii) ask for a copy of their Personal Information to be provided to them, or a third party, in a digital format. If you wish to exercise one of the above-mentioned rights, please send us your request to the contact details set out below. Individuals also have the right to lodge a complaint about the processing of their Personal Information with their local data protection authority.

 

California Residents Privacy Statement

Last Updated: August 15, 2023

 

Pursuant to the California Consumer Privacy Act of 2018 (as amended from time to time, the “CCPA”), this privacy statement provides details regarding the categories of Personal Information about California consumers that Enel X Way has collected, used and disclosed in the preceding 12 months. 

 

This privacy statement applies to California residents from or about whom our Company obtains Personal Information (collectively, “you” or “your”).  This privacy statement does not cover how our company processes the Personal Information of our employees, which is covered through a separate internal statement and notice.

 

This privacy statement may change from time to time.  Please check this privacy statement periodically for updates.

 

What is Personal Information?

References to “Personal Information” in this privacy statement means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or California household, subject to certain exceptions provided under the CCPA. 

 

Categories of Personal Information Collected

The categories of Personal Information our company has collected about you within the past 12 months are as follows:

  • Identifiers such as real name, account name, postal address, email address, phone number, date of birth or other similar identifiers.
  • Characteristics of protected classifications under California or federal law such as age.
  • Visual information, including photographs that we may capture if you attend our events or that you provide to us and video surveillance footage when you visit our locations for the security of our buildings and sites and the safety of our personnel and guests.
  • Physical characteristics or description contained in identification documents such as driver licenses and passports.
  • Audio information captured in recorded calls or any voicemail messages you left with our company. 
  • Commercial information such as signature in agreements entered into with our company, payment information and transactional history.
  • Financial and tax information such as credit card number, bank account number, debit card number, invoicing information and information for tax form W-9.
  • Internet or other electronic network activity information, such as IP address, cookie data, browsing history and interactions with our websites, applications, systems and emails.
  • Professional or employment-related information.

 

Source of Personal Information

Personal Information about you is collected from the following sources:

  • directly from you;
  • third parties that we are in contract with, who provide us with your Personal Information;
  • our service providers, including software vendors, who collect your Personal Information on our behalf or who provide us with your Personal Information; and
  • publicly available databases and social media platforms.

 

Purpose for Collecting Personal Information

Personal Information about you is collected by our Company for the following purposes:

  • to communicate with you and respond to your inquiries; 
  • to support any potential or actual business relationship or commercial transaction with you;  
  • to perform the services or provide the products reasonably expected by you if you request those products or services;
  • to perform or receive services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying your information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services;
  • to perform marketing activities, such as providing you with marketing materials or information about or related to our company, inviting you to events and webinars, inviting you to participate in ways to support our company and entering you in our company’s prize drawings;  
  • to detect, monitor and protect against any applicable security incidents; 
  • to undertake activities to improve our operations including employee trainings, audit functions and research;  
  • to conduct internal research for technological development and demonstration
  • manage and maintain licenses, permits and authorizations applicable to our company’s business operations; 
  • to respond to law enforcement requests; and
  • to exercise our legal rights and comply with applicable law and regulations, including to meet our tax, legal and regulatory obligations. 

 

Sale or Sharing of Personal Information

Our Company does not sell Personal Information, and we have not sold Personal Information of California residents to third parties in the past 12 months, including any Personal Information of minors under 16 years of age.   Other than Personal Information collected through cookies or web trackers from a user’s internet activity with our websites (for which California residents have the right to opt out), we have not shared Personal Information with third parties for cross-context behavioral or targeted advertising in the past 12 months, including any Personal Information of minors under 16 years of age.  As used in this privacy statement, the terms “sell” and “share” have the meanings given to them in the CCPA.

 

Disclosure of Personal Information

In the past 12 months, the categories of Personal Information about you that our Company has disclosed to a third party for a business purpose are as follows:

  • Identifiers such as real name, account name, postal address, email address, phone number, date of birth or other similar identifiers.
  • Characteristics of protected classifications under California or federal law such as age.
  • Visual information, including photographs that we may capture if you attend our events or that you provide to us and video surveillance footage when you visit our locations for the security of our buildings and sites and the safety of our personnel and guests.
  • Physical characteristics or description contained in identification documents such as driver licenses and passports.
  • Audio information captured in recorded calls or any voicemail messages you left with our company. 
  • Commercial information such as signature in agreements entered into with our company, payment information and transactional history.
  • Financial and tax information such as credit card number, bank account number, debit card number, invoicing information and information for tax form W-9.
  • Internet or other electronic network activity information, such as IP address, cookie data, browsing history and interactions with our websites, applications, systems and emails.
  • Professional or employment-related information.

 

For each category of Personal Information identified above, the categories of third parties to whom we disclose or may disclose your Personal Information are the following:

  • our affiliates;
  • our service providers, including marketing, media and community relations providers, consultants, advisors, providers of software solutions, providers of hosting services, data solution providers, providers of information technology and related infrastructure services, background check vendors and account management and payment processing providers; 
  • financial institutions that support commercial transactions;
  • government, quasi-government and regulatory agencies and organizations requesting Personal Information with which our company needs to comply; and
  • other authorized parties, such as public utilities, in order to provide services to you.

 

Categories of Sensitive Personal Information Collected

In addition, the categories of Sensitive Personal Information (as defined under the CCPA) our Company has collected about you within the past 12 months are as follows: social security number, driver’s license number, state identification card number and/or passport number.

 

Source of Sensitive Personal Information:

Sensitive Personal Information about you is collected from the following sources: (i) directly from you, and (ii) our service providers or contractual partners who collect your Sensitive Personal Information on our behalf or who provide us with your Sensitive Personal Information.

 

Purpose for Collecting Sensitive Personal Information

Sensitive Personal Information about you is collected by our Company for the following limited purpose:

  • to perform the services or provide the products reasonably expected if you request those products or services;
  • to perform or receive services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying your information, processing payments, providing financing, providing analytic services, providing storage or providing similar services;
  • to help ensure security and integrity (to the extent the use of your Sensitive Personal Information is reasonably necessary and proportionate for such purposes);
  • for short-term, transient use; and
  • to undertake activities to verify or maintain the quality or safety of a service provided by the Company and to improve, upgrade or enhance our services.

 

No Sale or Sharing of Sensitive Personal Information

Our Company does not sell or share Sensitive Personal Information, and we have not sold or shared Sensitive Personal Information of California residents to third parties in the past 12 months, including any Sensitive Personal Information of minors under 16 years of age.

 

Disclosure of Sensitive Personal Information

In the past 12 months, the categories of Sensitive Personal Information about you that our Company has disclosed to a third party for a business purpose are as follows: social security number, driver’s license number, state identification card number and/or passport number.

 

For each category of Sensitive Personal Information identified above, the categories of third parties to whom we disclose or may disclose your Sensitive Personal Information are the following:

  • our service providers, including background check vendors and account management and payment processing providers;
  • financial institutions that support commercial transactions;
  • government, quasi-government and regulatory agencies and organizations requesting Sensitive Personal Information with which our company needs to comply; and
  • third parties, such as acquiring entities and their advisors, in connection with any merger, acquisition, bankruptcy or other transaction in which the third party assumes control of all or part of our company’s business.

 

Your Rights under the CCPA

If you are a California resident, you have the following rights with respect to your Personal Information (including your Sensitive Personal Information), subject to certain exceptions under the CCPA.  In certain cases, we may deny your request for reasons permitted by the CCPA. 

 

Right to Know What Personal Information is Being Collected

You have the right to request that our company disclose what Personal Information about you we collect, use or disclose. Specifically, once we receive and confirm your verifiable request (see Exercising Your Rights below), we will at your request disclose to you:  

  • Categories of Personal Information we collected about you.
  • Categories of sources from which your Personal Information is collected.
  • Our business or commercial purpose for collecting or sharing your Personal Information.
  • Categories of your Personal Information we disclosed for a business purpose.
  • Categories of third parties to whom your Personal Information was disclosed for a business purpose.
  • Specific pieces of Personal Information we collected about you.

 

Right to Request Deletion of Personal Information

You have the right to request that we delete any of your Personal Information that we collected from you. Once we receive and confirm your verifiable request (see Exercising Your Rights below), we will delete your Personal Information from our records (and if applicable, notify our service providers and contractors to delete your Personal Information from their records), unless an exception applies under the CCPA.  Note that we may deny your deletion request if retaining the Personal Information is reasonably necessary and permitted under the CCPA.

 

Right to Request Correction

 

 

You have the right to request that our company correct inaccurate Personal Information that our company maintains about you.

 

Right to Opt-Out of Sharing

For Personal Information collected by our company through cookies or web trackers from your internet activity with our websites, you have the right to opt out of us sharing such Personal information with third parties for cross-context behavioral advertising. You can exercise this right through our “Do Not Sell or Share My Personal Information” tool in our cookie banner.

 

Right of No Retaliation and Discrimination

You have the right exercise your rights under the CCPA free from discrimination and retaliation as prohibited by the CCPA, and our company will not unlawfully discriminate against you for exercising such rights, including but not limited to, by:

  • Denying you products or services.
  • Charging you different prices or rates for products or services, including through granting discounts or other benefits, or imposing penalties.
  • Providing you a different level or quality of products or services.
  • Suggesting that you may receive a different price or rate for products or services or a different level or quality of products or services.

 

 

Exercising Your Rights

If you are a California resident, you can exercise these rights by submitting a request to our company by emailing or calling our Company at:

 

Email: dataprotectionoffice-northamerica@enel.com

Phone: +1 (800) 359-6615

 

Exercising Your Rights via Authorized Agent

To submit a request as an authorized agent on behalf of a California resident who wishes to exercise these rights, you may use the same submission methods provided above. As part of our verification process, among other requests we may make, we will request that you provide your contact information, relationship to the California resident, documentation verifying your identity and documentation showing that you are authorized to act as a representative of the California resident (such as a power of attorney or signed written authorization from the California resident).

 

Verifiable Requests

The CCPA requires our Company to verify requests that we receive, and we may ask you to provide certain additional information for our Company to verify your request in accordance with the CCPA.  To submit a verifiable request, please include in your request:

 

  • Description of your request with sufficient detail that allows our Company to properly understand, evaluate, and respond to it.
  • Sufficient information that allows our Company to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.

 

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.  Making a verifiable request does not require you to create an account with us. We will use Personal Information provided in a verifiable request only to verify the requestor’s identity or authority to make the request.

 

Response Timing and Format

For verifiable requests made by California residents, we will respond to your request in a manner that is consistent with the CCPA. We will endeavour to provide an initial response to your request within 10 business days of receipt and will attempt to fulfil the request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

 

We will deliver our written response by mail or electronically, at your option.  Any disclosures we provide will cover only the 12-month period preceding our receipt of a verifiable request, unless you request a longer period and to the extent such longer period is required under the CCPA. The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable request unless it is excessive (in particular because of the repetitive nature of the requests) or manifestly unfounded. If we determine that the request warrants a reasonable fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

Do Not Track

Other than as noted here, we do not support “Do Not Track” browser settings at this time. 

 

California “Shine the Light” Notice

If you are a California resident, you may request information from our Company about certain disclosures of your personal information to third parties, as such terms are defined under California’s Shine the Light law (which is a different law with different rights from the CCPA).  For more information, please contact us at the Contact Information set out immediately below.

 

Contact Information

For any questions regarding our Company’s privacy policies and practices, please contact us at:

 

Email: dataprotectionoffice-northamerica@enel.com

Phone: +1 (800) 359-6615

 

Assistance for Disabled Individuals

Alternative formats of this privacy statement are available upon request to individuals with a disability.  For assistance, please contact our Company at:

 

Email: dataprotectionoffice-northamerica@enel.com

Phone: +1 (800) 359-6615

 

Notice at collection for California residents

Purpose and Scope

Under the California Consumer Privacy Act (“CCPA”), as amended from time to time, California consumers are entitled to certain notices and disclosures regarding the collection and use of their personal information.  This notice is intended to provide the notice at collection that is required under the CCPA. 

 

 

Enel X Way USA, LLC and its affiliates and subsidiaries (collectively, “Enel X Way,” “we,” “us”  “our” and “Company”) are providing this notice to California residents (“you”) in order to inform you of: (i) the categories of your personal information, including any sensitive personal information, that will or may be collected by Enel X Way and (ii) the purposes for which that personal information will or may be used by Enel X Way.

 

Personal Information To Be Collected

Categories of Personal Information:  The categories of your personal information that will or may be collected by Enel X Way are as follows:

 

  • identifiers such as real name, account name, alias, postal address, email address, phone number, date of birth or other similar identifiers;
  • characteristics of protected classifications under California or federal law such as age, gender and marital status;
  • visual information, including photographs that we may capture if you attend our events or that you provide to us and video surveillance footage when you visit our locations for the security of our buildings and sites and the safety of our personnel and guests;
  • physical characteristics or description contained in identification documents such as driver licenses and passports;
  • audio information captured in recorded calls or any voicemail messages you left with our Company;
  • commercial information such as signature in agreements entered into with our Company, payment information and transactional history;
  • financial and tax information such as credit card number, bank account number, debit card number, invoicing information and information for tax form W-9;
  • internet or other electronic network activity information, such as IP address, cookie data, browsing history and interactions with our websites, applications, systems and emails; and
  • professional or employment-related information.

 

Purposes for Collection and Use: Our Company will or may use the personal information identified above for the following purposes:

 

  • to communicate with you and respond to your inquiries;
  • to support any potential or actual business relationship or commercial transaction with you;
  • to perform the services or provide the goods reasonably expected by you if you request those services or those goods;
  • to perform or receive services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying your information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services;
  • to perform marketing activities, such as providing you with marketing materials or information about or related to our Company, inviting you to events and webinars, inviting you to participate in ways to support our Company and entering you in our Company’s prize drawings;  
  • to detect, monitor and protect against any applicable security incidents;
  • to undertake activities to improve our operations including employee trainings, audit functions and research; 
  • to conduct internal research for technological development and demonstration;
  • to manage and maintain licenses, permits and authorizations applicable to the Company’s business operations;
  • to respond to law enforcement requests; and
  • to exercise our legal rights and comply with applicable law and regulations, including to meet our tax, legal and regulatory obligations. 

 

Sale or Sharing of Personal Information: Other than any personal information collected through cookies or web trackers from your internet activity with our websites (for which you have the right to opt out), our Company will not (i) sell your personal information to a third party or (ii) share your personal information with a third party for cross-context behavioral or targeted advertising. 

 

Sensitive Personal Information to be Collected

Categories of Sensitive Personal Information:  The categories of your sensitive personal information that will or may be collected by our Company are: social security number, driver’s license number, state identification card number and/or passport number.

 

Purposes for Collection and Use: Our Company will or may use the sensitive personal information identified above for the limited purposes:

 

  • to perform the services or provide the products reasonably expected if you request those products or services;
  • to perform or receive services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying your information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services;
  • to help ensure security and integrity (to the extent the use of your sensitive personal information is reasonably necessary and proportionate for such purposes);
  • for short-term, transient use; and
  • to undertake activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the Company, and to improve, upgrade or enhance the services.

 

No Sale or Sharing of Sensitive Personal Information: Our Company will not (i) sell your sensitive personal information to a third party or (ii) share your sensitive personal information with a third party for cross-context behavioral or targeted advertising.

 

Retention Schedule

Our Company retains the personal information and sensitive personal information described above for as long as such information is reasonably needed or permitted to carry out the purposes for which such information was collected.  The criteria applied by our Company to determine our retention periods include:

 

  • business and commercial purposes for which the personal information is used and the length of time the information is reasonably necessary to achieve those purposes;
  • the length and time we have an ongoing relationship with you;
  • whether we have a legal obligation to retain the personal information or the information is otherwise is reasonably necessary to comply with our legal obligations or contractual commitments, (such as certain laws that require us to keep records of your transactions or communications for a certain period before we can delete them);
  • whether retention is advisable to preserve our legal rights, including to defend against potential legal claims (such as applicable statutes of limitations); and
  • the way personal information is maintained and flows through our systems and how best to manage the lifecycle of the information in light of the volume and complexity of our systems.

 

Our Contact Information

For any questions regarding this Notice or to request more information, please contact our Company at:

 

Email Address: dataprotectionoffice-northamerica@enel.com

Toll-Free Phone Number: 1-800-359-6615  

 

Assistance for Disabled Individuals

Alternative formats of this notice are available upon request to individuals with a disability.  For assistance, please contact our Company at:

 

Email Address: dataprotectionoffice-northamerica@enel.com

Toll-Free Phone Number: 1-800-359-6615

  • the way personal information is maintained and flows through our systems and how best to manage the lifecycle of the information in light of the volume and complexity of our systems.