Privacy Policy

The policy below is effective as of 10/14/2025

This policy explains the rights of California residents regarding the collection, use, sale, and sharing of their personal information under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). We may update and make changes to this policy, so we encourage you to review it periodically.

1. Key Terms. It would be helpful to start by explaining some key terms used in this policy:

We, us, our	Cohen Ventures, Inc., dba Energy Solutions
Our representative	Diane Walker – dwalker@energy-solution.com
Personal information	Any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular consumer or household.
Sensitive personal information	Personal information revealing a consumer's driver's license, utility account numbers, and precise geolocation only when included with a submitted installation photo, racial or ethnic origin.

2. Personal Information We Collect About You. In the preceding 12 months, we have collected the following categories and specific types of consumer personal information:

Categories of Personal Information	Specific Types of Personal Information Collected
Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number or other similar identifiers)	Name, address, email address, phone number, IP address, username, password, employment/organization information, website URL, and other information that you voluntarily transmit with your communication to us.
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, their name, address, telephone number, and employment or organization.	Name, address, email address, phone number, IP address, platform username, password, driver’s license, utility account number, precise geolocation only when included with a submitted installation photo, racial or ethnic origin, and other information that you voluntarily transmit with your communication to us.
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)	Type of equipment installed and its price.
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Website, application, or advertisement)	Total number of visitors to the site, the number of visitors to each page of the site, browser type, internet service provider, referring/exit pages, platform type, date/time stamp, and number of clicks, and other information provided by you and other users.
Geolocation data	IP address and precise geolocation only when included with a submitted installation photo.
Professional or employment-related information	Employment/organization information

3. How Your Personal Information is Collected. We collect most of this personal information directly from you—via our platform/website.

4. Why We Use Your Personal Information. We collect consumer personal information for the following business purposes:

To process incentive claims for you or for a distributor, contractor, manufacturer, or dealer who submitted an incentive claim on your behalf
Helping to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for these purposes;
Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing incentives, providing analytic services, providing storage, or providing similar services on behalf of the business or service provider;
Undertaking activities to verify or maintain the quality of a service that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service that is owned, manufactured, manufactured for, or controlled by the business;
To comply with our legal and regulatory obligations;
For the performance of our services provided to you or to take steps at your request before entering into a contract;
For our legitimate interests or those of a third party; or
Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for	Our reasons
To provide services to you	For the performance of our services promised to you and to authenticate you as a user on the platform, as well as to communicate with you via email when necessary
To prevent and detect fraud against you or Cohen Ventures, Inc. dba Energy Solutions	For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you
Conducting checks to identify our customers and verify their identity	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g., policies covering security and internet use	For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training, and quality control	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorized access and modifications to systems	For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations
Updating and enhancing customer records	For the performance of our services provided to you or to take steps at your request before entering into a contract and to comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products
External audits and quality checks, e.g., for accreditations and the audit of our accounts	For our legitimate interests or a those of a third party, i.e., to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations

5. Who We Share Your Personal Information With. In the preceding 12 months, we have shared consumers’ personal information with:

Service providers we use to help deliver our products and/or services to you;
Other third parties we use to help us run our business, such as marketing agencies or website hosts;

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers, contractors, and third parties to ensure they can only use your personal information to provide services to us and to you

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

We will not share your personal information with any other third party.

6. Categories of Personal Information We Sold or Shared. In the preceding 12 months, we may have shared the following categories of personal information:

Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, or other similar identifiers);
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, their name, address, telephone number driver’s license, and utility account number;
Characteristics of protected classifications under California or federal law;
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
Internet or other electronic network activity information (e.g., information regarding a consumer’s interaction with an Internet Website, application, or advertisement);
Geolocation data when an installation photo is submitted;

7. Categories of Personal Information We Disclosed for a Business Purpose. In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose:

Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, utility account number, or other similar identifiers);
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, their name, physical characteristics or description, address, telephone number, and driver’s license number;
Characteristics of protected classifications under California or federal law;
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Website, application, or advertisement);
Geolocation data when an installation photo is submitted;
Sensitive personal information

8. How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:

To comply with our contractual obligations with our clients;
To respond to any questions, complaints or claims made by you or on your behalf;
To show that we treated you fairly; or
To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

When it is no longer necessary to retain your personal information, we will delete or anonymize it.

9. Your Rights Under the CCPA/CPRA. You have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You	You have the right to know, and request disclosure of: The categories of personal information we have collected about you, including sensitive personal information; The categories of sources from which the personal information is collected; Our business or commercial purpose for collecting, selling, or sharing personal information; The categories of third parties to whom we disclose personal information, if any; and The specific pieces of personal information we have collected about you. Please note that we are not required to: Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or Provide the personal information to you more than twice in a 12-month period.
Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose	In connection with any personal information we may sell, share, or disclose to a third party for a business purpose, you have the right to know: The categories of personal information about you that we sold or shared and the categories of third parties to whom the personal information was sold or shared; and The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose. You have the right to opt-out of the sale of your personal information or sharing of your personal information for targeted behavioral advertising. Please note we do not share or sell your personal information for the purpose of targeted behavioral advertising.
Right to Limit Use of Sensitive Personal Information	You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to: Perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services; To perform the following services: (1) Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes; (2) Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with the business, if the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business; (3) Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business; and (4) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business; and As authorized by further regulations. You have a right to know if your sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. To limit the use of your sensitive personal information, please email privacy@energy-solution.com or call 888-560-2422.
Right to Deletion	Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: Delete your personal information from our records; and Direct any service providers or contractors to delete your personal information from their records. Direct third parties to whom the business has sold or shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort. Please note that we may not delete your personal information if it is reasonably necessary to: Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes; Debug to identify and repair errors that impair existing intended functionality; Exercise free speech, ensure the right of another consumer to exercise their right of free speech, or exercise another right provided for by law; Comply with the California Electronic Communications Privacy Act; Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; Comply with an existing legal obligation; or Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Right of Correction	If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.
Protection Against Retaliation	You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things: Deny goods or services to you; Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; Provide a different level or quality of goods or services to you; or Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

10. Your Rights Under the CCPA/CPRA. If you would like to exercise any of your rights as described in this Privacy Policy, you can do so by emailing privacy@energy-solution.com. You may also call us at 888-560-2422.

Please note that you may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period.

If you choose to contact us directly, you will need to provide us with:

Enough information to identify you (e.g., your full name, address and customer or matter reference number);
Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.