Last Updated: 04/12/2018
This Policy will address the following:
- What information Smart Savings Rewards Program gathers/tracks about You on the Online Venues.
- What Smart Savings Rewards Program does with the information it gathers/tracks on the Online Venues.
- With whom Smart Savings Rewards Program shares the information it gathers/tracks on the Online Venues.
- The Online Venues’ opt-out policies.
- Smart Savings Rewards Program’s policy on correcting and updating information.
- Smart Savings Rewards Program’s policy on deactivating Your name from our database.
The Online Venues are a valuable platform for Users to maximize their energy savings in the long-term using the Services, a modletⓇ (smart plug) to be installed on an air-conditioner and a Smart AC thermostat (together, a “smartAC kit”) and related software, or by connecting an eligible air-conditioning unit to the Smart Savings Rewards Program platform to participate in the Services. Users who agree to share their information enable the Services to work more effectively by permitting the Services to read the energy usage of Your appliances, thus allowing the Services to recommend schedules for appliance usage based on the collected energy information or permit You to participate on certain days and at the times selected by the Smart Savings Rewards program in demand response events ("Events") during the summer period (generally May 1 through September 30) as described in the applicable Terms of Service for the program You enroll in. Opting out of sharing the energy usage information associated with Your appliances limits the functionality of the modlet and Services, prevents You from fully understanding how You can most effectively limit energy use, and may disqualify you from being able to keep the smartAC kits without charge or from earning any incentives associated with the program. By visiting/using the Online Venues (whether or not You are a registered member), You acknowledge and agree that we may share anonymous demographic information such as Your zip code, age, gender and the names of the electronic devices and appliances that You use. You can also opt out from our ability to share such anonymous demographic information. However, if You choose not to provide this anonymous demographic information, You might not be able to take advantage of many of the Site’s useful features.
By visiting/using the Online Venues (whether or not You are a registered member), You consent to the data practices described in this Policy. This Policy describes what information we gather from You, how we use that information, and what we do to protect it. If You do not want information about You to be used in the manner set forth in this Policy, please do not use the Online Venues.
This Policy is incorporated into and is subject to the applicable enrollment agreement You executed to participate in the program. The use of the Online Venues and any personal information that You provide to Smart Savings Rewards Program are subject to the terms of this Policy and Your enrollment agreement.
Information We Collect:
We may provide an online application and/or order form to process Your request for Services and/or entry in a Sweepstakes. Understand that the information that You submit is voluntary, but is required if You request Services and/or enter one of our Sweepstakes, whether or not You purchase our Services. Information submitted in connection with Your registration on any form, information associated with You that Smart Savings Rewards Program may collect in connection with credit card processing performed by us and/or third parties providing such services, and any and all other information we collect, confirm or gather in connection with Your registration/application, or otherwise, both online and offline, is referred to, collectively, herein as “Information.” Upon registration, Users may be required to provide all or some of the following Information:
- Company Name
- E-mail Address
- Billing Address
- Shipping Address
- Modlet Address
- Proof of Purchase/Verification Information (for rebates and incentives)
- Daytime Telephone Number and/or Cellular Telephone Number
- Credit Card Information (number, expiration date, security number)
- Answers to survey questions, including providing information (or authorizing us to locate information) concerning Your appliances and energy usage.
From time to time, Smart Savings Rewards Program may also ask You optionally to provide other information. If You choose to provide such information, during registration or otherwise, You are giving Smart Savings Rewards Program the permission to use and store such information consistent with this Policy. Therefore, please understand that when You sign in with Smart Savings Rewards Program, You are not anonymous to us. Smart Savings Rewards Program reserves the right to use, transfer and/or sell aggregate or group data about Smart Savings Rewards Program Users for lawful purposes. Aggregate or group data is data that describes the demographics, usage or other characteristics of Smart Savings Rewards Program Users as a group without disclosing personally identifiable information. Subject to applicable state and federal law, by submitting Your Information to, and/or using, the Online Venues, You agree to allow Smart Savings Rewards Program to transfer and/or sell such aggregate data to third-parties. Registrants for our Services may receive e-mail confirming their registration with Smart Savings Rewards Program, Service-related e-mail messages, as well as promotional marketing of commercial products and services. Registrants for our Sweepstakes may receive e-mail confirming their registration with Smart Savings Rewards Program, subsequent entries in our Sweepstakes, as well as promotional marketing of commercial products and services.
Energy Usage/Appliance/Electronic Device Information: Smart Savings Rewards Program collects certain information regarding the energy usage associated with those of Your electronic devices and appliances that You interface with the modlet and the platform, as well as information about the model, type and make of those electronic devices and appliances (collectively, “Energy Use and Appliance Information”).
Automatically Collected Information: When You access Smart Savings Rewards Program Services, our servers automatically record information that Your browser sends whenever You visit an Online Venue. These server logs include information such as Your web request, Internet Protocol address, browser type, browser language, the date and time of Your request and one or more cookies that may uniquely identify Your browser.
Information from Other Sources: We may also obtain information, including personally identifiable information, from third parties and sources other than the Online Venues. If we combine or associate information from other sources with personally identifiable information that we collect through the Online Venues, we will treat the combined information as personally identifiable information in accordance with this Policy.
Behavioral Tracking: Smart Savings Rewards Program does not place cookies or other tracking technology on the Online Venues that tracks users’ activities after they leave the Online Venues.
The Ways Smart Savings Rewards Program Uses Information:
- Smart Savings Rewards Program may process personal information for such purposes that include, but are not limited to; billing, shipping, account verification, sending You information related to the Services, verifying and updating Your Smart Savings Rewards Program account or other Smart Savings Rewards Program products and/or services, auditing, research and analysis in order to maintain, protect and improve our Services, ensuring the technical functioning of our network. This personal information helps us keep You posted on the latest product announcements, software updates, and other important Smart Savings Rewards Program information that You might like to hear about.
- Smart Savings Rewards Program uses Your Energy Use and Appliance Information to conduct Events, maintain, protect and improve our Services and the functionality of our equipment, as well as to provide You with energy saving advice, tips and recommendations.
- Smart Savings Rewards Program uses all of the information that we collect from Users to understand and analyze the usage trends and preferences of our Users, to improve the way the Online Venues work and look, and to create new features and functionality.
- Should You send email or other communications to Smart Savings Rewards Program, we may retain those communications in order to process Your inquiries, respond to Your requests and improve our Services.
- To the extent that Smart Savings Rewards Program collects Your credit card information, we will use that information to process and complete any Services-related transactions that You request per the terms of Your applicable enrollment agreement. We may use third party service providers to process credit card transactions, and such third parties may gain access to Your credit card information in connection with such services; provided, however, that such third service providers may only use Your credit card information to provide the applicable credit card processing service and not for any other purpose. By submitting Your credit card information to us, You authorize Smart Savings Rewards Program to periodically verify that Your credit card account continues to be a valid and active one by charging, and thereafter immediately crediting, a small sum to the card. Such verification may be conducted through a third-party and, in that case, Smart Savings Rewards Program would share Your specific credit card information with this third-party for verification purposes. Apart from said uses, we will not share Your credit card information with any third-parties (other than as set forth above and with consumer credit agencies) without Your prior informed consent. Notwithstanding the foregoing, Smart Savings Rewards Program reserves the right to share with third-parties the fact that we have credit card information on file for specific users, but we will not share Your specific credit card information with third-parties without Your prior informed consent.
Anonymous Aggregated Data:
- Anonymous data is information (originally personally identifiable or non-personally identifiable) that subsequently is used in aggregate form. We may collect anonymous data whether or not You are a registered member of Smart Savings Rewards Program. We may use anonymous data for purposes of research or analysis. We may conduct research on our customer demographics, Internet usage, and interests and behavior based on personal data we gather. Although anonymous data may be based in part on personal data, it does not identify You personally.
- Smart Savings Rewards Program may share this type of anonymous data with a variety of third parties, including its affiliates, advertisers and other current and prospective business partners. Smart Savings Rewards Program may use anonymous data collected for Online Venue administration, advertising and promotional purposes, and we may share such information with various affiliated and unaffiliated entities for such purposes. We may also enter into agreements with outside companies that possess technology that allows us to customize the advertising and marketing messages that You receive while using the Online Venues. Your non-personally identifiable information and click stream data about Your activities may be shared with these companies so this customization can be accomplished. Our agreements with these companies prohibit them from sharing Your information with any third party or using it for any other purpose. Anonymous click stream and demographic information may also be shared with our advertisers and business partners.
- Smart Savings Rewards Program may also use Energy Use and Appliance Information anonymously in the aggregate to understand how Users use their electronic devices and appliances. This anonymous Energy Use and Appliance Information may be sold to third parties, such as appliance manufacturers that seek to make more efficient appliances, utilities that want to create more accurate demand models, state or local governments that want to track energy usage by appliance type or User demographic and energy auditors that want to benchmark client data, among others.
- Smart Savings Rewards Program may also use anonymous Energy Use and Appliance Information to assess if certain appliances and/or electronic devices earn a Smart Savings Rewards Program eco-rating certification, as well as to select advertisers for the Online Venues.
When Smart Savings Rewards Program Discloses Information:
- We have Your consent. We require that our Users opt-out of consenting for the sharing of general demographic information.
- Smart Savings Rewards Program discloses automatically collected and other aggregate non-personally-identifiable information with interested third parties to assist such parties in understanding the usage, viewing, and demographic patterns for certain programs, content, services, advertisements, promotions, and/or functionality on the Online Venues.
- Smart Savings Rewards Program’s authorized employees, agents and contractors must have a legitimate business reason to obtain access to the personally identifiable information that You may provide to register for the Services. We may share Your personally identifiable information with companies that provide services to us, including outside contractors or agents who help us manage our information activities or provide the Services, but they may only use Your personally identifiable information to provide us with a specific service and not for any other purpose.
- If required by law or we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to: (a) satisfy any applicable law, regulation, legal process or enforceable governmental request; (b) enforce applicable Terms of Service, including investigation of potential violations thereof; (c) detect, prevent, or otherwise address fraud, security or technical issues; or (d) protect against harm to the rights, property or safety of Smart Savings Rewards Program, its Users or the public as required or permitted by law. In some cases, we may make such disclosures without first providing notice to Users.
- If ThinkEco becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we reserve the right, in any of these circumstances, to transfer or assign the information that we have collected from Users as part of such merger, acquisition, sale, or other change of control.
How We Protect Your Personal Information:
Smart Savings Rewards Program uses commercially reasonable measures to secure Your personal information from unauthorized access, use, disclosure or destruction. When our registration/application process asks users to enter sensitive information, and when we store and transmit such sensitive information, that sensitive information is encrypted and is protected with SSL encryption software. We cannot, however, ensure or warrant the security of any information that You transmit to Smart Savings Rewards Program, and You do so at Your own risk. Once we receive Your transmission of information, Smart Savings Rewards Program makes commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. All of our Users’ personal information, not just sensitive information, is restricted in our offices. Only employees who need the information to perform a specific job (for example a customer service representative) are granted access to personal information. Our employees are dedicated to ensuring the security and privacy of all Smart Savings Rewards Program Users’ personal information. Employees not adhering to our security policies are subject to disciplinary action.
If Smart Savings Rewards Program learns of a security systems breach, then we may attempt to notify You electronically so that You can take appropriate protective steps. We may post a notice on the Smart Savings Rewards Program Site if a security breach occurs. Depending on where You live, You may have a legal right to receive notice of a security breach in writing.
Smart Savings Rewards Program processes personal information only for the purposes for which it was collected and in accordance with this Policy. From time to time, we review our data collection, storage and processing practices to ensure that we only collect, store and process the personal information needed to provide or improve our Services. We take reasonable steps to ensure that the personal information we process is accurate, complete and current, but we depend on our Users to update or correct their personal information whenever necessary. We encourage You to keep Your personal information and preferences current by regularly updating Your Smart Savings Rewards Program account.
Accessing and Updating Personal Information:
When You use Smart Savings Rewards Program, we make good faith efforts to provide You with access to Your personal information and either to correct this data if it is inaccurate or to delete such data at Your request if it is not otherwise required to be retained by law or for legitimate business purposes. We ask individual Users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we provide information access and correction free of charge, except if doing so would require a disproportionate effort.
We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required.
Please be advised that instructing us to delete Your personal information will only result in the deletion of the personal information contained in our database. This deletion will not change or delete personal information which may have already been shared with third parties, all as provided above in this Policy. You will need to contact the third parties that contact You directly to change Your preferences regarding their use of Your personal information.
You are responsible for maintaining the secrecy of Your unique password and account information at all times.
Links to Third Party Websites:
This Policy only applies to the Online Venues. We do not exercise control over the websites to which the Online Venues and/or the Services link. These other websites may place their own cookies or other files on Your computer, collect data or solicit personal information from You. We encourage our Users to read the privacy policies of any third-party website that they visit. It is the sole responsibility of such third parties to adhere to any applicable restrictions on the disclosure of Your personally identifying information, and Smart Savings Rewards Program, ThinkEco and its affiliates are not liable for wrongful use or disclosure of Your personally-identifying information by these third parties.
Our Commitment to Children’s Privacy:
Visitors under eighteen (18) years of age are not permitted to use the Online Venues, submit their personal information at the Online Venues and/or use the Services. Smart Savings Rewards Program does not knowingly solicit or collect information from visitors under eighteen (18) years of age. Smart Savings Rewards Program encourages parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.
If You are a parent or guardian and discover that Your child under eighteen (18) years of age has obtained a Smart Savings Rewards Program account, then You may alert Smart Savings Rewards Program by emailing us through the Site at https://www.smartsavingsroomac.com/ and request that Smart Savings Rewards Program delete that child’s personal information from its systems.
This Policy may be revised periodically without further notice to You and this will be reflected by a “Last Updated” date above. Smart Savings Rewards Program will also archive on the Online Venues old versions of this Policy should we make any changes. Please revisit this page to check in frequently to see recent changes to this Policy. If the manner in which we use personally identifiable information changes, Smart Savings Rewards Program will notify its Users by posting the updated Policy on the Site and: (a) sending the modified Policy to its Users via email; and/or (b) by any other reasonable means acceptable under applicable state and federal law. You will have a choice as to whether or not we use Your information in this different manner. At any time that You do not agree with the changes, You must opt out from receiving future communications from us (see the “Opt-Out/Unsubscribe” section below). Failure to opt out after notice of any such changes constitutes an affirmative acknowledgement and acceptance by You of the modified Policy.This Policy may be revised periodically without further notice to You and this will be reflected by a “Last Updated” date above. Smart Savings Rewards Program will also archive on the Online Venues old versions of this Policy should we make any changes. Please revisit this page to check in frequently to see recent changes to this Policy. If the manner in which we use personally identifiable information changes, Smart Savings Rewards Program will notify its Users by posting the updated Policy on the Site and: (a) sending the modified Policy to its Users via email; and/or (b) by any other reasonable means acceptable under applicable state and federal law. You will have a choice as to whether or not we use Your information in this different manner. At any time that You do not agree with the changes, You must opt out from receiving future communications from us (see the “Opt-Out/Unsubscribe” section below). Failure to opt out after notice of any such changes constitutes an affirmative acknowledgement and acceptance by You of the modified Policy.
To stop receiving future communications from Smart Savings Rewards Program, please click here. During registration, application, purchase and/or when You otherwise submit personal information to Smart Savings Rewards Program, You have opted-in and authorized us to share Your personal information (other than credit card information) with third-parties for marketing purposes as set forth above. When contacted by any of these companies or third parties, You should notify them directly of Your choices regarding their use of Your information. To opt-out of having Your personal information shared with third-parties, please contact us at: click here. To opt-out of having Your Energy Use and Appliance Information shared with third-parties, please contact us at: click here. When contacted by any of these companies or third parties, You should notify them directly of Your choices regarding their use of Your information.
Smart Savings Rewards Program Contact Information:
If You have any questions about this Policy, please click here, or write to us at Smart Savings Rewards Program, 335 Madison Ave, 4th Floor, New York, NY 10017.
Filing a Complaint with the Federal Trade Commission:
To file a complaint regarding our privacy practices, please click here.