Privacy Notice

The Narragansett Electric Company d/b/a Rhode Island Energy, a PPL corporation (referred to in this notice as “Rhode Island Energy”. RI Energy”, “RIE”, “Narragansett,” the “Company,” “we,” “us,” or “our”), developed this Privacy Notice “Notice” to make our customers (referred to as “Users,” “you” or “your”) familiar with how we collect, use and disclose information. This Notice describes our practices in connection with information that we collect through the following:

• Websites operated by us or our third-party service providers from which you are accessing this Notice (collectively, the “Websites”);
• Our social media pages (collectively, our “Social Media Pages”); and
• HTML-formatted email messages that we send to you that link to this Notice or other communications with you.

Collectively, we refer to the Websites, Social Media Pages and emails as the “Services.”

This Notice does not apply to information that you may provide to Rhode island Energy other than through our Services or that Rhode island Energy may obtain through means other than our Services (such as over the phone, by mail, or in person).

By providing any information to us, and by accessing and using Services, you agree that you have read and understand this Notice and that you accept and consent to the privacy practices and uses or disclosures of information about you that are described herein. If you do not agree with this Notice, please do not use the Services or provide us with any personal information.

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. The Services collect Personal Information, including:

• Name
• Postal address (including billing and shipping addresses)
• Telephone number
• Email address and password
• Social Security number/ Taxpayer ID (including Employer Identification Number or EIN)
• IP address (we may also derive your approximate location from your IP address)
• Bank account information
• Payment card data
• Payment plan information
• Transaction, billing, and payment history
• Utility account number
• Energy information, such as electricity kWh usage, therms, electricity or gas supplier, rate class along with other information that identifies you as an individual
• Personal characteristics such as photographic image, fingerprints, handwriting or other unique biometric data
• Services, including Website(s) usage information that identifies you as an individual

By giving a telephone number to us you agree that a representative of Rhode Island Energy can contact you at the number you provide, potentially using automated technology (including texts/SMS messaging) or a pre-recorded message. Your consent is not an obligation to receive any of our products and/or services.

Collection of Personal Information

We and our service providers collect Personal Information in a variety of ways, including:

• Through the Services.
  We collect Personal Information through the Services, for example, when you create or register an account to access the Services, pay your utility bills, track your utility usage, apply for a rebate, report an outage, fill out customer agreements or other forms, contact customer service, or fill out an order form.
• From Other Sources.
  We may receive your Personal Information from other sources, for example:
• from third party service providers, when they share your energy management system, devices, or appliance information.
• joint marketing partners, when they share the information with us.

We need to collect Personal Information to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Notice.

Use of Personal Information

We and our service providers use Personal Information for the following purposes:

• Contacting you.
• Providing the functionality of the Services and fulfilling your requests.
• To provide the Services’ functionality to you, such as arranging access to your registered account, maintenance of your registered account, and providing you with related benefits, special promotions, information relating the Company and the Services or customer service.
• To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request a quote for or other information about our Services or our business.
• To provide information relating to the Services, for example regarding service outages and restoration, for example through email updates, texts alerts, and pre-recorded calls.
• To complete your transactions, verify your information, and provide you with related benefits, special promotions, or customer service.
• To send administrative information to you, such as changes to our terms, conditions, and policies.
• Providing you with our newsletter and/or other marketing materials and facilitating social sharing.
• To send you marketing related emails, with information about our services, new products and other news about our company or business.
• Analyzing Personal Information for business reporting and providing personalized services.
• To analyze or predict our users’ preferences so we can improve our Services.
• To better understand your interests and preferences, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.
• To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.
• Allowing you to participate in sweepstakes, contests or other promotions.
• We may offer you the opportunity to participate in sweepstakes, contests or other promotions.
• Some of these promotions have additional rules containing information about how we will use and disclose your Personal Information. Please read those additional rules before choosing to participate.
• Aggregating and/or anonymizing Personal Information.
• We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information pursuant to applicable law(s). We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.
• We may use such aggregated and/or anonymous Personal Information to create business and marketing insights to improve our business.
• Accomplishing our business purposes.
• For data analysis, for example, to monitor usage, traffic, and improve the efficiency of our Services;
• For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements;
• For security purposes including efforts to prevent and investigate illegal activities and violation of this Notice, for fraud prevention and fraud security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
• For developing new products and services;
• For enhancing, improving, repairing, maintaining, or modifying our current products and Services, as well as undertaking quality and safety assurance measures;
• For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;
• For billing purposes, including reporting and collecting debts;
• For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and
• For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.

Where we disclose Personal Information to our service providers for a purpose set forth herein, we enter a contract with the third party that describes the purpose and requires the third party to both protect and secure Personal Information and not use it for any purpose except performing under the contract.

If we are permitted to utilize targeted marketing campaigns under applicable laws, regulations and/or orders, we will not use your information to target, segment, or profile individuals based on health (including pregnancy), negative financial status or condition, political affiliation or beliefs, racial or ethnic origin, religious or philosophical affiliation or beliefs, sexual orientation or gender identity, trade union membership, data relating to alleged or actual commission of a crime, or for any unlawful or discriminatory purpose or in a manner that would be inconsistent with your reasonable expectation of privacy or in violation of applicable laws. We will not use Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you with notice and/or updating this Notice.

Disclosure of Personal Information

We disclose Personal Information:

• To our affiliates for the purposes described in this Notice.
• To our third party service providers, to facilitate services they provide to us.
• These can include providers of services such as website hosting, data analysis, payment processing, order fulfillment, return authorization, fraud prevention, information technology and related infrastructure provision, customer service or related benefits (including special promotions), email delivery, auditing, and other services.
• This includes Rhode Island Energy and/or its affiliates who act as our service provider to provide the Services to you.
• To third parties, to permit them to send you marketing communications, consistent with your choices, unless you opt-out from marketing communications.
• To third party sponsors of sweepstakes, contests, and similar promotions.
• By using the Services, you may elect to disclose Personal Information:
• When you ask us to allow another person (i.e., a relative) to access your account.
• When you ask us to share your account information with a third party to monitor energy usage data.
• As permitted by law to perform credit checks, report or collect debts owed, or protect the rights or property of Rhode Island Energy, our Services, and our Users.

Other Uses and Disclosures

We also use and disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:

• To comply with applicable law and regulations.
• This may include laws outside your jurisdiction.
• To cooperate with law enforcement.
• For example, when we respond to law enforcement requests and orders or provide information we believe is important.
• For other legal reasons.
• When we are contractually obligated to disclose your information;
• This may include sharing energy usage data with energy suppliers as required by law;
• To enforce our terms and conditions; and/or
• To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
• In connection with a sale or business transaction.
• We have a legitimate interest in disclosing or transferring your Personal Information to a third party when we evaluate or conduct any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Services collect Other Information such as:

• Browser and device information
• Information collected through cookies, pixel tags and other technologies (if such information is not associated with a particular individual or user)
• Demographic information and other information provided by you that does not reveal your specific identity
• Information that has been aggregated in a manner such that it no longer reveals your specific identity

Collection of Other Information

We and our service providers may collect Other Information in a variety of ways, including:

• Your browser or device.
• Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services you are using, the referring page that linked you to the Services, the pages, content, or ads you see or click on during your visit and when and for how long you do so, items you download, the next Web site you visit when you leave the Services, and any search terms entered on the Services or a referral site. We use this information to ensure that the Services function properly.
• Dynatrace is a tool that monitors the performance of our website and other customer systems, as well as user behaviors. Cookies placed by Dynatrace on the devices of website visitors may collect Website usage data, web browser type/version, operating system, Website visit information. To learn more about Dynatrace and your data privacy please visit https://www.dynatrace.com/company/trust-center/privacy/.
• Cookies.
• Cookies are pieces of information stored directly on the device that you are using. Our Services use session ID cookies and persistent cookies. A session ID cookie is temporary and allows users to complete a form. Once you close your browser, the cookie terminates. A persistent cookie is stored on a device’s hard drive for an extended period and can be removed by following Internet browser “help” file directions. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other usage and traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them. Cookies further allow us, or may also be used by our marketing partners, to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Services. We may also use cookies or other technologies in online advertising to track responses to our ads. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html, or visit the Network Advertising Initiative’s website at http://www.optout.networkadvertising.org for more information. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services. You also may not receive advertising or other offers from us that are relevant to your interests and needs.
• Pixel tags and other similar technologies.
• Pixel tags. Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates. Some of our third party service providers who provide data analytics services through our Services use pixel tags to collect standard internet log information and web site user behavior.
• Invisible reCAPTCHA. We use Google’s invisible reCAPTCHA application on our Services to protect against spam and other automated abuse. The reCAPTCHA tool may make use of cookies, as well as other information like IP address, date, time, language, screen size and resolution, and mouse movements. The use of the reCAPTCHA tool and any information collected through the tool are subject to Google’s privacy policy, available at https://policies.google.com/privacy, and Google’s terms of service, available at https://policies.google.com/terms?hl=en.

Uses and Disclosures of Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

Rhode Island Energy has implemented a number of security features designed to protect against the unauthorized release of, or access to, Personal Information. For example, only authorized personnel, and that of its services providers, are allocated access to any stored Personal Information Rhode Island Energy may collect regarding its Users.

Moreover, when a User registers online or accesses his or her account information through the Services, Rhode Island Energy offers the User the ability to use a secure server. The secure server encrypts information a User inputs during its transmission to Rhode Island Energy.

We use SSL (or Secure Sockets Layer (TLS 1.2)) as our primary form of security protection. A Secure Sockets Layer is a protocol that hides the information sent between the browser and server. An SSL-enhanced browser uses encryption to scramble the transferring data you send to a website into randomized characters for decoding.

Most browsers will illustrate that you are entering or leaving a secure area by presenting a dialog box. However, most browsers also give you the option of turning off the dialog box display. We seek to use commercially reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure, and the transmission of such data is therefore entirely at your own risk. If you create an account on our Services, you are responsible for maintaining the strict confidentiality of your account password, and you shall be responsible for any activity that occurs using your account credentials, whether or not you authorized such activity. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.

Your choices regarding our use and disclosure of your Personal Information

We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt out from:

1. Receiving marketing-related emails from us. If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt out at any time by using the unsubscribe feature included in any such message. Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative and transactional communications, from which you cannot opt out.
2. Receiving text/SMS/mobile messages from us. After you provide prior express written consent to receive marketing text messages from us, if you no longer want to receive text/SMS/mobile messages from us on a going-forward basis, you may opt out at any time by contacting Rhode Island Energy, in accordance with the “Contact Us” section below, or by responding “STOP” to any such message.
3. Our sharing of your Personal Information with affiliates for their direct marketing purposes. If you would prefer that we discontinue sharing your Personal Information on a going-forward basis with our affiliates for their direct marketing purposes, you may opt out of this sharing by checking the appropriate box when the data is collected, or at any time by contacting Rhode Island Energy, in accordance with the “Contact Us” section below.
4. Our sharing of your Personal Information with unaffiliated third parties for their direct marketing purposes. If you would prefer that we discontinue sharing your Personal Information on a going-forward basis with unaffiliated third parties for their direct marketing purposes, you may opt out of this sharing by checking the appropriate box when the data is collected, or at any time by contacting Rhode Island Energy, in accordance with the “Contact Us” section below.

We will try to comply with your request(s) as soon as reasonably practicable and/or in accordance with applicable law(s).

How you can access, change, or delete your Personal Information

At any time, a User may contact Rhode Island Energy via postal mail or phone to request:

• a summary of any Personal Information retained by Rhode Island Energy regarding such User;
• a change to the User’s personal data record maintained by Rhode Island Energy; or
• removal of the User’s personal data record from Rhode Island Energy’s database.

You may send your requests in accordance with the “Contact Us” section below. We will respond to your request consistent with applicable law. In the event Rhode Island Energy receives such a request, Rhode Island Energy may require you to confirm or verify any change your personal record. Your right to delete your information is subject to our record retention policies and back-up procedures, and/or other legal exemptions.

This Notice does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked website or service by us or by our affiliates. When you leave the Services, we encourage you to read the privacy statements of each website or service.

We also contract with vendors to provide enhanced customer information through the Internet. These third party websites are not under the control of Rhode Island Energy, and we are not responsible for their contents. These websites have separate privacy and data collection practices, independent of Rhode Island Energy. We are not responsible or liable for these websites’ independent practices, policies or actions. If you provide any personal information while visiting these websites, you are solely responsible, and do so at your own risk.

In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with our Social Media Pages.

Third Party Advertising

We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services, which are displayed to you based on your activities on the Services.

• You may receive advertisements based on information relating to your access to and use of the Services and other websites or online services on any of your devices, as well as on information received from third parties. When this happens, these third parties automatically receive your IP address. These companies place or recognize a unique cookie on your browser (including through the use of pixel tags), which they may use to measure the effectiveness of their ads and to personalize ad content. They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. We do not have access to or control over cookies or other features that the third party advertisers may use, and the information practices of these third parties are not covered by our Notice. If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Notice, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#/. Please note that you have to opt-out using each of your desktop and mobile browsers and devices separately. Additionally, if you opt-out we may still suggest offerings to you on our Services based on your history with the Services.

The Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from individuals under 18.

No one under age 13 may submit or post any information, including Personal Information, on our Site. Under no circumstances may anyone under age 13 use our Site. Parents or legal guardians of children under 13 cannot agree to these terms on their behalf.

“Educational support” is a section of www.rienergy.com that includes links to external websites containing information directed at educating children about energy use and safety. Please see the section above, “Third Party Services.”

Your Right to Request Removal of Content

If a child provides us with personally identifiable information in violation of this Notice, a parent or guardian of that child may have that information deleted from our records (subject to our record retention and backup policies and procedures) by calling us at the telephone number below or writing to Rhode Island Energy, attention:

Internet/Privacy Notice, c/o Customer Experience
Rhode Island Energy, PO Box 25215, Lehigh Valley PA, 18002-5215
1-855-RIE743-1101

Your Personal Information may be stored and processed in any jurisdiction where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to locations outside of your jurisdiction of residence, including in the United States, which may have data protection rules that are different from those of your country.

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (i.e., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background) on or through the Services or otherwise to us. If you do send us such information, you do so at your own risk.

The Services may provide functionality allowing you to make payments to the Company using third party payment services. When you use such a service to make a payment to us your Personal Information will be collected by such third party and not by us, and will be subject to the third party’s privacy policy, rather than this Notice. We have no control over, and are not responsible for, this third party’s collection, use, and disclosure of your Personal Information. We do not process your payments.

Rhode Island Energy makes no guarantee, warranty or representation, express or implied (including implied warranties of merchantability and fitness for a particular purpose), with regard to the accuracy, completeness, usefulness, timeliness or suitability of the information being provided on our Services.

It is expressly understood and agreed that neither Rhode Island Energy nor its directors, officers, employees or agents shall assume any liability or responsibility for any damages or claims resulting from any use or disclosure of the information being provided on our Services.

We are committed to making sure that our Services are accessible to everyone. To access this Notice in an alternative form, please contact us at the phone numbers or e-mail address set forth in this Policy and we will assist you with your request. For more information, please see our Accessibility Statement www.rienergy.com/Accessibility.

We may modify this Notice at any time. The “Last Updated” legend at the bottom of this Notice indicates when this Notice was last revised. Any changes will become effective when we post the revised Notice on the Services. If we materially alter our Notice, we will provide you with direct notice of the change by posting a notice on our Website and/or an email notification. In some cases, we may request your consent to the changes if required by applicable law(s). Providing information to us after implementation of our new notice, and/or your continued use of the Services, will be deemed your agreement that your information may be used in accordance with the new notice. If you do not agree with the changes, then you should not provide additional information to us, stop using the Services and you should notify us that you do not want your information used in accordance with the changes.

The Narragansett Electric Company d/b/a Rhode Island Energy, a PPL corporation, is the company responsible for collection, use, and disclosure of your Personal Information under this Notice.

If you have any questions or complaints about this Notice, please contact us at:

Rhode Island Energy
PO Box 25215
Lehigh Valley PA, 18002-5215
1-855-7431101