Last revised and effective as of: March 11, 2021

This Privacy Policy applies to information collected online and offline by NRG Market Inc. (“NRG Market” "we" or “us” or “our”) through your use of the NRG Market website at nrgmarket.com and any subdomains thereof (the “Site”) and the services, features, and information available on the Site (together with the Site, along with associated and successor websites, applications, features, information, and services, or any part thereof, the “Service”). This Privacy Policy is incorporated into, and part of, and governed by the NRG Market Subscription Terms (the “Terms”).

You should carefully read this Privacy Policy. As used in this Privacy Policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within NRG Market or among our affiliates within the United States.

This Privacy Policy serves to notify you of the following:

What information about me is collected?

Where and when is information collected (including through the use of cookies and action tags)?

Is information submitted to the Public Areas of the Service private?

Does NRG Market collect information from children under 13 years of age?

What does NRG Market do with the information it collects?

When does NRG Market disclose information to third parties?

Does this Privacy Policy apply when I link to other websites or services?

Is the information collected through the Service secure?

Could my information be transferred to other countries?

For how long will my personally identifiable information be kept?

What choices do I have regarding my personally identifiable information?

How will I know if there are any changes to this Privacy Policy?

Who do I contact if I have any privacy questions?

WHAT INFORMATION ABOUT ME IS COLLECTED?
Depending on your use of the Service, we may collect two types of information: personally identifiable information and non-personally identifiable information.

Personally Identifiable Information
Personally identifiable information is information that identifies you or can be used to identify or contact you. Such information may include your name, user identification, password, e-mail address, telephone number, company name, company address, company telephone number, any personally identifiable information you upload or post to the Public Areas of the Service.

Non-Personally Identifiable Information
Non-personally identifiable information is information, any single item of which, by itself, cannot be used to identify or contact you, including non-identifiable demographic information, browser types, unique device identifiers, device types, requested URL, referring URL, browser language, the pages you view, the date and time of your visit, domain names, and statistical data involving the use of the Service. Certain non-personally identifiable information may be considered a part of your personally identifiable information if it were combined with other identifiers in a way that enables you to be identified. However, the same pieces of information are considered non-personally identifiable information when they are taken alone or combined only with other non-personally identifiable information (for example, your viewing preferences) in a way that would not enable you to be identified.

WHERE AND WHEN IS INFORMATION COLLECTED (INCLUDING THROUGH THE USE OF COOKIES AND ACTION TAGS)?
We will collect personally identifiable information that you submit to us. We may also collect personally identifiable information that is publicly available through sources such as LinkedIn.

Registering to Use the Service and in the Course of Using the Service.
You may be required to establish an account in order to take advantage of certain features of the Service. If so, if you wish to establish an account you will be required to provide us and/or our third-party service provider with information (including personally identifiable information and non-personally identifiable information) such as name, email address, telephone number, company name, company address, company telephone number, user identification, and password. In addition, we may obtain your personally identifiable information from you if you identify yourself to us by sending us an e-mail with questions or comments. Also, we will have access to any personally identifiable information that you choose to share through the Service, including any information you choose to upload or post in the Public Areas of the Service.

If you choose to access the Service using your Google or Microsoft account, you are providing us with access to all information, attributes, and data, including without limitation your access token, e-mail address, first and last name, link, [gender, id, and location in the applicable social media public profile, as well as any other information in the applicable social media account that you have granted NRG Market permission to access] (“Social Profile Information”). We may store and use such Social Profile Information in accordance with this Privacy Policy and the Terms. For the avoidance of doubt, all information in your NRG Market account (which, if you choose to access the Service through social media will include your Social Profile Information) will be stored by NRG Market and will be used in connection with providing the Service, to contact you, [and to identify you to other users of the Service (such as when you communicate within the Service, and will be part of the Public Areas (as defined below) of the Service and available to other users of the Service].

If you are a representative of a property owner, and you choose to access certain features of the Service, you may be required to provide information concerning the physical attributes of your property, including (in addition to its street address, city or town, and ZIP Code), information regarding the current electric usage and charges, and property square footage.

If you are a representative of a property developer, and you choose to access certain features of the Service, you may be asked to provide a summary of services you provide and any property attributes or requirements you want to communicate regarding your development projects.

Cookies and Action Tags
We may collect information passively using “cookies” and “action tags.”

“Cookies” are small text files that can be placed on your computer or mobile device in order to identify your web browser and the activities of your computer on the Service and other websites. Cookies can be used to personalize your experience on the Service (such as dynamically generating content on webpages specifically designed for you), to assist you in using the Service (such as saving time by not having to reenter your name each time you use the Service), to allow us to statistically monitor how you are using the Service to help us improve our offerings, and to target certain advertisements to your browser which may be of interest to you or to determine the popularity of certain content.

You do not have to accept cookies to use the Service. Although most browsers are initially set to accept cookies, you may reset your browser to notify you when you receive a cookie or to reject cookies generally. Most browsers offer instructions on how to do so in the "Help" section of the toolbar. However, if you reject cookies, certain features or resources of the Service may not work properly or at all and you may experience some loss of convenience.

For the avoidance of doubt, the Service uses third-party service platforms (including for authentication services and to help analyze how users use the Service). These third-party service platforms may place cookies on your computer or mobile device. If you would like to disable "third party" cookies, you may be able to turn them off by going to the third party's website.

Here is a link to the main third-party platforms we use:
https://www.google.com/policies/privacy/
https://www.linkedin.com/legal/cookie-policy
https://legal.hubspot.com/cookie-policy
https://auth0.com/privacy#cookie-policy

"Action tags," also known as web beacons or gif tags, are a web technology used to help track website usage information, such as how many times a specific page has been viewed. Action tags are invisible to you, and any portion of the Service, or e-mail sent on our behalf, may contain action tags.

By using cookies and action tags together, we are able to gain valuable information to improve the Service and measure the effectiveness of our marketing campaigns. Information collected from some cookies placed on the website is used to deliver advertisements to NRG Market site visitors when such visitors are visiting other websites.

Finally, you should be aware that third parties may use their own cookies or action tags when you click on a link to their websites or services on or from the Service. This Privacy Policy does not govern the use of cookies or action tags or the use of your information by such third-party websites or services or providers of third-party advertising

Log Files
We also collect information through our Internet log files, which record data such as user IP addresses, browser types, domain names, and other anonymous statistical data involving the use of the Service. This information may be used to analyze trends, to administer the Service, to monitor the use of the Service, and to gather general demographic information. We may link this information to personally identifiable information for these and other purposes such as personalizing your experience on the Service and evaluating the Service in general.

Public Areas
The Service features various community areas and other public forums (the "Public Areas") where Service users with similar interests can share information and support one another or where members can post questions for others to answer. These Public Areas are open to all users with accounts and should not be considered private. We cannot prevent information included within a Public Area from being used in a manner inconsistent with this Privacy Policy, the law, or your personal privacy. We are not responsible for the results of such postings or for the accuracy of any information contained in those postings.

Any information you share in a Public Area (including personally identifiable information) is by design open to all accountholder users of the Service and is not private. You should think carefully before posting any information in any Public Area. What you post can be seen, disclosed to or collected by others and may be used by others in ways we cannot regulate or predict. As with any public forum on any website, the information you post may also show up in third-party search engines like Google, Yahoo, MSN, and Bing. If you mistakenly post personally identifiable information in a Public Area you can send us an e-mail to request that we remove it by contacting us at privacy @ nrgmarket (.) com. You should understand that in some cases, we may not be able to remove your information.

IS INFORMATION SUBMITTED TO THE PUBLIC AREAS OF THE SERVICE PRIVATE?
No. Any information shared in the Public Areas of the Service is available to the public, including to all users. Such information is not protected or treated as confidential, can be used in any manner, and is not subject to this Privacy Policy. If you wish to keep any information private or proprietary, do not submit it to the Public Areas of the Service. NOTWITHSTANDING THE FOREGOING, WE HAVE NO RESPONSIBILITY OR LIABILITY IF A USER’S INFORMATION OR IDENTITY IS MISUSED OR STOLEN, OR IF A USER SUFFERS HARM AS A RESULT OF VOLUNTARY DISCLOSURES.

DOES NRG MARKET COLLECT INFORMATION FROM CHILDREN UNDER 13 YEARS OF AGE?
We are committed to protecting the privacy of children. The Service is not designed for or directed to children under the age of 13. We do not collect personally identifiable information from any person we actually know is under the age of 13. In fact, as currently operated persons under the age of 18 may not use the Service. By providing information to NRG Market, you represent that you are 18 years of age or older.

WHAT DOES NRG MARKET DO WITH THE INFORMATION IT COLLECTS?
We will only use your personally identifiable information to the extent that the law allows us to do so. We use the information collected to provide the Service to you and process your transactions, to help us understand who uses the Service, for internal operations such as operating and improving the Service, to contact you for customer service and billing purposes, and, unless you opt out, so that we and third parties acting on our behalf can contact you about products and services that may be of interest to you. In addition, we will facilitate introductions between property owners and developers through the Service by providing contact and property information of a property owner to a developer, when the property owner selects a developer through the Service.

We may use your information to send you a welcoming e-mail that may confirm your user name and password. Unless you opt out, we and third parties acting on our behalf may subsequently send you electronic newsletters, contact you about the Service, products, services, information and news that may be of interest to you, and provide you with targeted feedback. If you no longer desire to receive these communications, we will provide you with the option to change your preferences in each communication we send to you. You may also inform us by email to: privacy @ nrgmarket (.) com.

If you identify yourself to us by sending us an e-mail with questions or comments, we may use your information (including personally identifiable information) to respond to your questions or comments, and we may file your questions or comments (with your information) for future reference.

We may also use the information collected to send announcements and updates regarding the Service or, if applicable, about your billing account status. You will not be able to unsubscribe from these Service announcements and updates as they contain important information relevant to your use of the Service and are necessary for the performance of our contract with you.

We may also use the information gathered to perform statistical analysis of user behavior or to evaluate and improve the Service. We may link some of this information to personally identifiable information for internal purposes or to improve your experience with the Service.

WHEN DOES NRG MARKET DISCLOSE INFORMATION TO THIRD PARTIES?
We generally disclose information we gather from you through the Service to the following types of third parties and as otherwise set forth in this Privacy Policy or our Terms or as specifically authorized by you.

Laws and Legal Rights.
We may disclose your information (including personally identifiable information) if we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, lawful requests by public authorities, including to meet national security or law enforcement requirements, or other valid legal process. We may disclose personally identifiable information in special circumstances when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating the Terms or another contract with us, to detect fraud, for assistance with a delinquent account, or to protect the safety and/or security of our users, the Service or the general public.

Third Parties Generally.
We may provide to third parties non-personally identifiable information, including where such information is combined with similar information of other users of the Service. For example, we might inform third parties regarding the number of unique users who use the Service, the demographic breakdown of our users of the Service, or the products and/or services purchased using the Service and the vendors of such products and services.

In addition, we will facilitate introductions and transactions between property owners and developers through the Service by providing contact and property information of a property owner to a developer, if the property owner has opted in.

In addition to the above, when users use our Service, third parties (including without limitation authentication service providers, third-party analytics service providers and commercial partners) may directly collect personally identifiable and non-personally identifiable information about our users’ online activities over time and across different websites. The third parties to which we may provide or who may independently directly collect personally identifiable and non-personally identifiable information may include providers of services (including vendors, authentication services providers, analytics services providers, and website tracking services), affiliates and other actual or potential commercial partners, and other similar parties. Please note in particular that the Service uses Google Analytics, including its data reporting features. Information collected by Google Analytics includes but is not limited to web metrics. For information on how Google Analytics collects and processes data, please see the site “How Google uses data when you use our partners' sites or apps”, currently located at www.google.com/policies/privacy/partners/. For information on opting out of Google Analytics, we encourage you to visit Google’s website, including its list of currently available opt-out options presently located at https://tools.google.com/dlpage/gaoptout.

Outside Contractors.
We may employ independent contractors, vendors and suppliers (collectively, "Outside Contractors") to provide specific services and products related to the Service, such as hosting and maintaining the Service, providing authentication services, and developing applications for the Service. In the course of providing products or services to us, these Outside Contractors may have access to information collected through the Service, including your personally identifiable information. We use reasonable efforts to ensure that these Outside Contractors are capable of protecting the security of your personally identifiable information.

Sale of Business.
We reserve the right to transfer information to a third party in connection with a sale, merger or other transfer of all or substantially all of the assets of NRG Market or any of its Corporate Affiliates (as defined below), or that portion of NRG Market or any of its Corporate Affiliates to which the Service relates, or in connection with a strategic investment by a third party in NRG Market,or in the event that we discontinue our business or file a petition or have filed against us a petition in bankruptcy, reorganization or similar proceeding.

Affiliates.
We may disclose information (including personally identifiable information) about you to our Corporate Affiliates. For purposes of this Privacy Policy: "Corporate Affiliate" means any person or entity which directly or indirectly controls, is controlled by or is under common control with NRG Market, whether by ownership or otherwise; and “control” means possessing, directly or indirectly, the power to direct or cause the direction of the management, policies or operations of an entity, whether through ownership of fifty percent (50%) or more of the voting securities, by contract or otherwise.

DOES THIS PRIVACY POLICY APPLY WHEN I LINK TO OTHER WEBSITES OR SERVICES?
Our Service may provide you with access to other websites and services. Please be aware that we are not responsible for the privacy practices of any websites or services other than the Service. A link to a third party website does not constitute or imply endorsement by us. Additionally, we cannot guarantee the quality or accuracy of information presented on those websites. We encourage you to read the privacy policies or statements of each and every such website and service. This Privacy Policy applies solely to information collected by us through the Service.

IS THE INFORMATION COLLECTED THROUGH THE SERVICE SECURE?
We want your information (including personally identifiable information) to remain secure. We strive to provide transmission of your information from your computer or mobile device to our servers through techniques that are consistent with commercially reasonable standards and to employ administrative, physical, and electronic measures designed to protect your information from unauthorized access.

Notwithstanding the above, you should be aware that there is always some risk involved in transmitting information over the Internet. There is also some risk that others could find a way to thwart our security systems. As a result, while we strive to protect your information, we cannot ensure or warrant the security or privacy of any information you transmit to us, and you do so at your own risk.

COULD MY INFORMATION BE TRANSFERRED TO OTHER COUNTRIES?
Personally identifiable information collected on the Service may be transferred from time to time to our offices or personnel, or to third parties, located throughout the world, and the Service may be viewed and hosted anywhere in the world, including countries that may not have laws of general applicability regulating the use and transfer of such information. By using the Service and submitting such information on it, you voluntarily consent to the trans-border transfer and hosting of such information. If you are a user accessing the Service from a jurisdiction with laws or regulations governing personal data collection, use, and disclosure that differ from those of the United States, please be advised that all aspects of the Service are governed by the internal laws of the United States and the Commonwealth of Massachusetts, USA, regardless of your location.

FOR HOW LONG WILL MY PERSONALLY IDENTIFIABLE INFORMATION BE KEPT?
We will only retain your personally identifiable information for as long as necessary to fulfill the purposes for which we collected it.

To determine the appropriate retention period for personally identifiable information, we consider the amount, nature, and sensitivity of that information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your personally identifiable information and whether we can achieve those purposes through other means, and the applicable legal requirements.

WHAT CHOICES DO I HAVE REGARDING MY PERSONALLY IDENTIFIABLE INFORMATION?
We generally use personally identifiable information as described in this Privacy Policy or our Terms or as authorized by you or as otherwise disclosed at the time we request such information from you. You generally must "opt in" and give us permission to use your personally identifiable information for any other purpose. You may also change your preference and "opt out" of receiving certain marketing communications from us by following the directions provided in association with the communication or such other directions we may provide or by contacting privacy @ nrgmarket (.) com.

If you want to review, verify, correct or request erasure of your personally identifiable information, object to the processing of your personally identifiable information, or request that we transfer a copy of your personally identifiable information to another party, please contact privacy @ nrgmarket (.) com.

Such updates, corrections, changes and deletions will have no effect on other information that we maintain, or information that we have provided to third parties in accordance with this Privacy Policy prior to such update, correction, change or deletion. To protect your privacy and security, we may take reasonable steps (such as requesting a unique password) to verify your identity before granting you profile access or making corrections. You are responsible for maintaining the secrecy of your unique password and account information at all times.

You should be aware that it may not be technologically possible to remove each and every record of the information you have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of your personally identifiable information may exist in a non-erasable form that will be difficult or impossible for us to locate. After receiving your request, we will use commercially reasonable efforts to update, correct, change, or delete, as appropriate, all personally identifiable information stored in databases we actively use and other readily searchable media as appropriate, as soon as and to the extent reasonably practicable.

DO NOT TRACK
The term “Do Not Track” refers to a HTTP header offered by certain web browsers to request that websites refrain from tracking the user. We take no action in response to automated Do Not Track requests. However, if you wish to stop such tracking, please contact us with your request, using our contact details provided below.

HOW WILL I KNOW IF THERE ARE ANY CHANGES TO THIS PRIVACY POLICY?
We may revise this Privacy Policy from time to time. We will not make changes that result in significant additional uses or disclosures of your personally identifiable information without allowing you to “opt in” to such changes. We may also make non-significant changes to this Privacy Policy that generally will not significantly affect our use of your personally identifiable information, for which your opt-in is not required. We encourage you to check this page periodically for any changes. If any non-significant changes to this Privacy Policy are unacceptable to you, you must immediately contact us and, until the issue is resolved, stop using the Service.

WHO DO I CONTACT IF I HAVE ANY PRIVACY QUESTIONS?
If you have any questions or comments about this Privacy Policy or feel that we are not abiding by the terms of this Privacy Policy, please contact us in any of the following ways:

By e-mail:
privacy @ nrgmarket (.) com

By postal mail or courier:
Attn: Privacy 

NRG Market, Inc.

93 Clarke Circle
Needham, MA 02492