Privacy Policy

(Last updated on March 12, 2015)

Introduction

C3, Inc. (hereinafter "C3 Energy") respects each individual's right to personal privacy. We will collect and use information we receive directly from you through our web site only in the ways disclosed in this Privacy Policy. This Privacy Policy applies solely to information we collect directly from you on the C3 Energy web site www.C3energy.com (the "Web Site"). Information provided to C3 Energy by our corporate customers is collected by those customers under their own privacy policies. This policy does not apply to practices that C3 Energy does not own or control, or to individuals that C3 Energy does not employ or manage. By visiting the Web Site, you acknowledge that you accept the practices and policies outlined in this Privacy Policy.

C3 Energy provides a family of smart grid analytics software as a service (SaaS) solutions for energy companies. C3 Energy receives and processes information (in paper and electronic form) in accordance with its customers’ instructions for the purpose of providing its SaaS solutions to its customers. At C3 Energy, we recognize the importance of privacy to our customers and we strive to safeguard any personal information we receive and may need to use in support of our customers.

C3 Energy adheres to the set of data protection principles developed by the United States Department of Commerce (DOC), in collaboration with the European Commission and the Federal Data Protection and Information Commissioner of Switzerland, which produced the U.S.-European Union Safe Harbor Framework Documents and U.S.-Swiss Safe Harbor Framework Documents. The privacy principles in this policy are based on these Safe Harbor Principles and are further articulated in the C3 Energy Safe Harbor Privacy Policy (“Safe Harbor Policy”) available at http://safeharborpolicy.c3energy.com that sets out the privacy principles to which C3 Energy adheres, including as it relates to personal information transferred from the European Union (“EU”) and/or Switzerland to the United States (“U.S.”).

This published Privacy Policy, in combination with the Safe Harbor Policy, is accurate, comprehensive, prominently displayed, completely implemented, accessible, and conforms to the Safe Harbor Principles. A statement verifying the self-assessment is signed by a corporate officer or other authorized representative of the organization annually.

This Privacy Policy does not govern or apply to C3 Energy’s products or services themselves, or any C3 Energy customers' use of C3 Energy SaaS solutions to collect information.

Information Collection

C3 Energy collects the following information through the Web Site session data and information that you enter on the Web Site or provide to us in any other way. We also provide “Live Chat” sessions on our Web Site to assist you while you’re navigating through our Web Site. We will use personal information you provide via these sessions in accordance with this Privacy Policy. Individuals are free to change the personal information that C3 Energy has collected from them and to unsubscribe from any and all C3 Energy communications at any time by stating such preferences in an email to privacy@c3energy.com. The manner in which we collect this information is described below.

Session Data

We collect information on the pages you have visited and the contents of those pages, any information you input, your referring URL or IP address, your time of visit and related session information, your requested page, Web browser type, USR agent, status of request (successful reply), cookies, number of bytes in the response, and query string. We use this data to better understand Web site usage in the aggregate so that we know what areas of our Web site users prefer. This information is stored in log files and is used for aggregated and statistical reporting.

Cookies

C3 Energy uses cookies. Cookies are small text files placed on your computer by a Web site. Cookies enable C3 Energy to track usage patterns and deliver customized content to users. These cookies cannot read information from your hard drive. C3 Energy uses cookies to collect and store your User ID. The User ID is not personally identifiable to you. The information is only used to identify repeat visitors. C3 Energy also uses temporary session cookies to assign and store a Session ID to you so that you can move uninterrupted between areas of our Web Site. C3 Energy also uses the Session ID for internal reporting purposes. This Session ID is not personally identifiable to you and this type of cookie does not leave any retrievable information on your hard drive. The User ID does not have an expiration date. Session IDs expire when the browser is closed.

Please note that clicking a link within a C3 Energy email may result in a cookie being placed on your computer/device. If you do not wish to receive a cookie from a link in an email or on the C3 Energy Web Site, you may, depending on your browser version, elect to block all cookies. Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. We recommend that you leave the cookies activated.

Registration and Questionnaires

For visitors interested in registering to download a document or participating in a marketing campaign offering, we ask that they register with us by supplying their name and basic contact information, including email address. C3 Energy verifies that the email address conforms to standard email address requirements. C3 Energy may also ask you to provide information about your:

• Title

• Company

• Phone Number

Mailing List

C3 Energy also has a voluntary mailing list where users can supply their email address to facilitate periodic communications from C3 Energy. Individuals that voluntarily register for the mailing list are automatically subscribed to the C3 Energy voluntary mailing list.

C3 Energy does not actively market to children, and we never knowingly ask a child under 18 to divulge personal information. If a child under 13 submits personal information to C3 Energy and we learn that the personal information is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any personal information from a child under 13, please contact us at privacy@c3energy.com. 

Information Collection Purposes

The information we collect is used to improve the content of our Web Site, to notify registered site visitors about news or updates with respect to our company and/or products and services.

Please let us know if you do not want to receive email from us in the future by sending an email to us at privacy@c3energy.com and telling us that you do not want to receive email from our company.

If you supply us with your postal address online, you may receive periodic mailings from us with information on new products and services or upcoming events. Please let us know if you do not wish to receive such mailings by sending an email to us at privacy@c3energy.com. Please provide us with your exact name and address. We will be sure your name is removed from the list.

Information Usage

The information collected by C3 Energy will be used for:

• Sales initiatives; and

• Marketing initiatives

Registered users and those who sign up to receive communications from us will receive a periodic C3 Energy company newsletter, and occasional email announcements regarding company activities.

Registered users will receive additional announcements from us about products, services, and a newsletter. Out of respect for the privacy of our users we present the option to not receive these types of communications.

We offer links to other Web sites. Please note that when you click on links to other Web sites, you are leaving the C3 Energy Web Site and may be subject to different rules, including, but not limited to, different privacy policies that may be less protective of your privacy. We encourage you to read the privacy policies that govern the Web sites you may link to from our Web Site.

Access to Information

C3 Energy maintains the accuracy of our information by requiring password registration to download C3 Energy material. Users may access their own personal information and contact us about inaccuracies they may find by emailing such request to privacy@c3energy.com. Users may delete their information from our database by emailing such request to privacy@c3energy.com.

Third Parties

C3 Energy uses third parties to help us conduct our business, such as sending news headlines and providing database management. We will only give a third party your information for the purpose that you have specified, such as fulfilling a request. Whenever you do business with another company, including one you have clicked on from C3 Energy, you should read their privacy policy to ensure that they are protecting your personal information. Their standards may differ from ours.

C3 Energy may also store and disclose personal information as allowed or required by applicable law, including making disclosures that are necessary or advisable to: (a) protect the rights, safety or property of users of our Web Site, the public, or C3 Energy or our suppliers; and (b) conform to legal or regulatory requirements.

International Users - Applicable Law

Please note that the personal information you submit to us may be transferred to the United States and other countries to be processed by us in order to provide this Web Site to you or for such other purposes as set forth in this Policy. If you are not a resident of the United States, you consent and agree that we may collect, process, use, and store your personal information, as discussed in this Policy, outside your resident jurisdiction, including in the United States. Please be aware that United States law and laws of other countries where we may store and process your data may offer different levels of protection for personal information than may be available in your country.

C3 Energy has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.  To learn more about the Safe Harbor program, and to view C3 Energy’s certification, please visit http://www.export.gov/safeharbor/

Business Transfers

In some cases, C3 Energy may choose to buy or sell corporate assets or securities. In these types of transactions, customer information is typically one of the business assets that is transferred. Moreover, if C3 Energy, or substantially all of its assets or securities were acquired, or in the unlikely event that C3 Energy goes out of business or enters bankruptcy, customer information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and hereby consent and agree that any acquirer of C3 Energy may continue to use your personal information as set forth in this policy.

Changes to Privacy Policy

We may notify all customers via email of changes to this Privacy Policy, by posting the changes on our Web Site. Please check this page for changes from time to time to make sure you are aware of our latest privacy practices. Any choices you have made about how your information may be used will continue to be respected in the event of such a change.

Problem Resolution

If problems arise, users may contact C3 Energy by emailing privacy@c3energy.com. We are committed to resolving disputes within ninety (90) days.

Data Storage and Security

C3 Energy takes reasonable steps to protect the data we collect from unauthorized access, disclosure, alteration, or destruction. We do this by implementing industry standard security procedures for storing and accessing information. However, you should be aware that we cannot ensure that all of your private communications and other personally identifiable information will never be disclosed in ways not otherwise described in this Privacy Policy. By way of example (without limiting the foregoing), we may be forced to disclose information to the government or third parties under certain circumstances, third parties may unlawfully intercept or access transmissions or private communications, or users may abuse or misuse your information that they collect from our site.

If you have any further questions about privacy or security, please contact us by sending an email to: privacy@c3energy.com.

© 2015 C3 Energy. All rights reserved.

C3 Energy Safe Harbor Privacy Policy

Introduction

This Safe Harbor Privacy Policy (“Policy”) applies to all personal information received by C3, Inc. dba C3 Energy (“C3 Energy”) from residents of the EU or Switzerland. In most cases, the data we receive will be in electronic form and relates to our customers and its end users. It may include personal information about our customers’ employees, business contacts, clients, and any other individuals with whom our customers have dealings. When we receive and process personal information provided to us by our customers, we do so as a “data processor” acting on the instructions of our customers and/or the court system as “data controllers.”

Definitions

  1. Collectively, “Information” means “Personal Information” that (1) is transferred from the EU or Switzerland to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual; and/or “Sensitive Personal Information” that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership, or that concerns an individual’s health.
  2. “Agent” is any third party that collects, uses, or stores Information in support of C3 Energy engagements.

Safe Harbor Principles

The practices to which C3 Energy is committed are based on the EU and Swiss Safe Harbor Principles negotiated between their respective government agencies and the United States Department of Commerce. Adherence by C3 Energy to these Safe Harbor Principles provides the necessary level of protection required by the EU/Swiss Directives for the transfer of personal information outside the EU/Switzerland. C3 Energy’s execution of these principles may be limited in certain circumstances, in particular:

(a) where there is a conflicting or overriding legal obligation;

(b) to the extent expressly permitted by any applicable law, rule or regulation; or

(c) where C3 Energy receives personal information as a “data processor” acting on the instructions of a customer. As C3 Energy will be receiving personal information from the EU/Switzerland merely for processing, its principle obligations are limited to onward transfer, security, access, and enforcement. C3 Energy’s customer remains responsible for notice, choice, and data integrity.

Notice: C3 Energy receives data to be processed and/or stored, the contents of which may, or may not be Information. Notice should be provided in clear language by the data controller when individuals are first asked to provide Information to the data controller, which will then be passed to C3 Energy.

Choice: C3 Energy does not collect Information, therefore it relies on the data controller to offer individuals the opportunity to choose (opt-out) whether their Information is:

(a) to be disclosed to a third party (unless that disclosure is allowed or required by contract), or

(b) to be used for a purpose that is not consistent with the purpose for which that

Information was originally collected, or subsequently authorized by the individual.

C3 Energy expects each data controller to provide individuals with reasonable mechanisms to exercise their choices.

Onward Transfers: In the event C3 Energy transfers Information, it will obtain assurances from its Agents, prior to such transfer, that they will safeguard the Information in a manner consistent with this Policy. Every Agent utilized enters into a contractual relationship with C3 Energy, which includes confidentiality and non-disclosure clauses, and provides the same level of commitment to and protections, as required by the Safe Harbor Principles. 

Security: C3 Energy takes reasonable precautions to protect Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. C3 Energy utilizes commercially accepted security equipment, techniques, procedures, and contractual measures to control, monitor and record access to any facility containing Information or any third party receiving Information. 

Data Integrity: C3 Energy will use Information only in ways that are relevant and compatible with the purpose for which that information was collected or provided to C3 Energy. C3 Energy will take reasonable steps to ensure that all data collected, processed and/or stored is protected from destruction, corruption, or use in a manner inconsistent with the purpose for which it received the information.

Access: Upon request, and where permissible by law and purpose for which it possesses the Information, C3 Energy will grant individuals reasonable access to Information that it holds about them. In addition and where permissible, C3 Energy will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete, except where the burden or expense of providing access would be disproportionate to the risks of the individual’s privacy, or where the rights of another individual may be violated. A reasonable fee may be charged as compensation for our expenses incurred in accessing, changing, or deleting the personal information.

Enforcement: C3 Energy will conduct compliance audits at least annually of its relevant privacy practices to verify adherence to this Policy and will self-certify with the US Department of Commerce. Further, C3 Energy will conduct follow up investigations to verify that attestations and assertions regarding practices are true. Violations and/or complaints may be made to C3 Energy via email to privacy@c3energy.com and C3 Energy engages in training to support implementation and compliance. Any employee that C3 Energy determines is in violation of this Policy will be subject to disciplinary action.

Dispute Resolution: Questions or concerns regarding C3 Energy’s use or disclosure of Information may be directed to the C3 Energy General Counsel at the address given below. C3 Energy will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Information in accordance with the principles contained in this Policy. For Complaints that cannot be resolved between C3 Energy and the complainant, C3 Energy agrees to cooperate with Data Protection Authorities located in the EU or Switzerland (or their authorized representatives) and participate in any dispute resolution procedures established by such authorities pursuant to the Safe Harbor Principles.

Contact Information

Please refer all questions or comments regarding this Policy to:

C3 Energy
Attention: Vice President and General Counsel
1300 Seaport Boulevard, Suite 500, Redwood City, CA 94063
650-503-2200
legal@c3energy.com

This Safe Harbor Policy is available at safeharborpolicy@c3energy.com.

Changes To This Safe Harbor Privacy Policy

This Policy may be amended from time to time to remain consistent with the requirements of the Safe Harbor Principles and other applicable laws.

The effective date of this Safe Harbor Privacy Policy is: March 12, 2015