Effective Date: January 1, 2020
Last Reviewed: December 26, 2019
Your privacy is a top priority for QCS and we make every reasonable effort to protect the information we hold about you. This Privacy Policy addresses information obtained from California consumers (California residents), QCS customers, website visitors, and mobile application users and is intended to inform you about how QCS treats personal information that we collect and use about you. This Policy covers Quality Conservation Services and its parent company, Free Energy Savings Company LLC. As used herein, “QCS” refers to Quality Conservation Services and/or Free Energy Savings Company LLC.
Except as noted in this Privacy Policy, this Privacy Policy does not apply to employment-related personal information collected from California-based job applicants, employees, directors, officers and contractors.
In addition to QCS’s general privacy policies, California consumers and QCS customers who are California residents have specific rights under the California Consumer Privacy Act of 2018.
The rights include:
You may exercise your rights under the California Consumer Privacy Act as described in more detail below. You can also download a copy by visiting
Verifiable requests may be submitted in writing to:
QCS Corporate Administration Center
Attn: Privacy Management
4751 East Arrow Highway
Montclair, CA 91763
Definitions
“Personal information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household or QCS customer. Such information may be subject to confidentiality requirements.
“Service providers” means any entity other than QCS that processes information on behalf of QCS and/or to which QCS discloses a consumer’s personal information for a business purpose pursuant to a written contract, including the host or sponsoring utilities.
“Third parties” means any person or entity other than QCS or its employees, which collects, uses or accesses personal information from QCS for any purpose other than a business purpose on behalf of QCS.
“You” means any California consumer, QCS customer, website visitor, or mobile application user.
Information We Collect and Disclose About QCS Customers and California Consumers
If permitted by law, we collect information about you from a variety of sources, including:
For some applications and or for analysis, we link service and energy information with your personal information.
We may supplement the information described above with information we obtain from other sources, including from both online and offline data providers. Such supplemental information may include contact information, such as your email address, demographic data, or other relevant information.
In particular, within the preceding twelve (12) months, QCS may have collected, through its website or otherwise, and disclosed to service providers and third parties the categories of personal information identified below in order to provide services to our customers, as required by law, or otherwise. Of particular interest may be that all of the information we have is normally provided to, or available upon request from, the host utilities with whom we have contracts or the regulatory agencies which have authority over those utilities, QCS or the goods and services provided.
The categories of personal information identified below include the categories of personal information about our customers, including California consumers as well as QCS job applicants, employees, directors, officers and contractors. In addition to QCS, service providers and host utilities, third parties to whom personal information may be disclosed on behalf of QCS may include contractors, vendors, service providers, government regulatory agencies, courts, and other third parties with a legal right to the information, as well as marketing, advertising and analytic companies. See also Information we obtain from your use of our website or mobile apps and How We Use Information below.
A. Identifiers
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, utility account number(s), Social Security number, driver’s license number, passport number, or other similar identifiers.
Yes
C. Protected classification characteristics under California or federal law
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Yes
C. Protected classification characteristics under California or federal law
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Yes
D. Commercial information
Records of personal and real property, products or services provided, obtained, or considered, or other purchasing or consuming histories or tendencies.
Yes
E. Biometric information
Physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information.
Yes
F. Internet or similar network activity
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Yes
G. Geo-location data
Physical location or movements.
Yes
H. Sensory Data
Audio, electronic, visual, thermal, olfactory, or similar information.
Yes
I. Professional or employment-related information
Current or past job history or performance evaluations.
Yes
J. Non-public education information
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Yes
K. Inferences drawn from other personal information
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Yes
For some applications and or for analysis, we link service and energy information with your personal information.
We may supplement the information described above with information we obtain from other sources, including from both online and offline data providers. Such supplemental information may include contact information, such as your email address, demographic data, or other relevant information.
In particular, within the preceding twelve (12) months, QCS may have collected, through its website or otherwise, and disclosed to service providers and third parties the categories of personal information identified below in order to provide services to our customers, as required by law, or otherwise. Of particular interest may be that all of the information we have is normally provided to, or available upon request from, the host utilities with whom we have contracts or the regulatory agencies which have authority over those utilities, QCS or the goods and services provided.
The categories of personal information identified below include the categories of personal information about our customers, including California consumers as well as QCS job applicants, employees, directors, officers and contractors. In addition to QCS, service providers and host utilities, third parties to whom personal information may be disclosed on behalf of QCS may include contractors, vendors, service providers, government regulatory agencies, courts, and other third parties with a legal right to the information, as well as marketing, advertising and analytic companies. See also Information we obtain from your use of our website or mobile apps and How We Use Information below.
Utilities, Service Providers, Vendors, Contractors Which Provide Equipment, Products, Services and Plans to Support QCS’s Services, Products and Programs Provided to Consumers and For Other Necessary Business Purposes
Third Parties Receiving Personal Information Pursuant to a Valid Legal Warrant, Subpoena, Court Order or Legal or Regulatory Mandate, or Necessary for QCS to Defend or Assert Legal Claims
Host Utilities, Regulatory Agencies, including the California Public Utilities Commission, California Energy Commission, and Federal, State or Local Agencies or Representatives with Authority to Obtain the Information
First responders and other government entities during public safety emergencies
Financial institutions, credit agencies, and other financial services entities providing financial and auditing support services for QCS’s programs and services
Service Providers, Contractors, Vendors and Other Third Parties Which Provide Support for QCS General Business Processes and Purposes
Sharing Personal Information at Your Choice
You may authorize other companies or persons to receive your personal information from QCS, including the services and products provided to you. The cost to QCS of providing this requested information to another party shall be the responsibility of you and/or the recipient. Before sharing information, it is important that you understand how other parties intend to use your information, if they will share it with others, and your rights as a consumer.
Selling Personal Information
QCS has not sold consumers’ personal information in the preceding 12 months for any monetary value and does not intend to sell in the future for any monetary value. However, we could be involved in programs that could be considered a “sale” under the California Consumer Privacy Act, such as in connection with our contractual responsibility to provide certain information on our participating consumers to the host utilities or their representative. This is an integral and necessary part of the services we provide to our consumers.
QCS does not and will not sell the personal information of minors under 16 years of age without affirmative authorization.
Click the “Do Not Sell My Personal Information” button on the website you have visited to direct QCS to continue to not sell your personal information without your consent.
Retention
We retain your personal information based on legal requirements or business needs. Generally, we only retain personal information for as long as is reasonably necessary for our business purpose or as required by law. Secure disposal methods are used when information is no longer needed.
Accessing and Managing Your Personal Information
To provide you with quality service, we rely on you to provide us with complete and accurate information. If you think the information we have about you is inaccurate or outdated, you may contact us to update or correct the information. You may update or correct your information by writing to us at the address listed in the “Contact Us” of our website.
We offer certain choices about how we communicate with you and what Personal Information you provide to us. In some cases, you have the right to limit, or opt-out of, the information you provide to us.
Your Rights and Choices under the California Consumer Privacy Act
As indicated above, the California Consumer Privacy Act provides California consumers (California residents) with specific rights regarding their personal information. This section describes your rights under the California Consumer Privacy Act and explains how to exercise those rights.
Access to Personal Information Upon a Verified Request
You have the right to request that QCS disclose certain information to you about our collection and use of your personal information over the past 12 months.
You may review those rights, including submitting a verifiable request to access the personal information by writing to us at the following address:
QCS Corporate Administration Center
Attn: Privacy Management
4751 East Arrow Highway
Montclair, CA 91763
Once we receive and confirm your verifiable consumer request (see Exercising Your Access, Data Portability, and Deletion Rights), we will disclose to you:
Deletion Request Rights
In addition, you have the right to request that QCS delete any of your personal information that we collected from you, subject to certain exceptions, including when required to be retained by law or for our essential business or public utility purposes, such as providing services or products to you. These exceptions include record retention schedules and other requirements mandated by the California Public Utilities Commission, the California State Licensing Board, our agreement with your host utility, or other legally binding authority that effectively prohibit deletion of certain personal information.
Once we receive and verify your consumer request, we will delete your personal information from our records, unless an exception applies.
Exercising Your Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a written request, providing us with information to verify your identity, to:
QCS Corporate Administration Center
Attn: Privacy Management
4751 East Arrow Highway
Montclair, CA 91763
QCS cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request and whenever feasible, we will match the provided identifying information to the personal information in our possession from the past 12 month. If you wish to authorize a third party to make a request on your behalf, you must contact the QCS directly and must provide a valid California power of attorney or comparable documentation of written permission from you and verification of your identity with QCS. Such power of attorney must meet the requirements of Probate Code sections 4000 to 4465.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period.
You may also make a verifiable consumer request on behalf of your minor child.
Response Timing and Format
We will respond to a verified consumer request for personal information within 45 days of receipt. If we require more time (up to 45 additional days), we will notify you of the reason and extension period in writing. We will deliver our written response by mail or email address submitted by you and through a secure link, at your preference. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response will also explain the reasons we cannot comply with a request, if applicable.
For data portability requests, we will select a format to provide your personal information that is reasonably useable for transmittal of the information from one entity to another entity.
We may charge a reasonable fee, to the extent allowed, to cover our costs to process or respond to a verifiable consumer request, but will notify the requesting party of the estimated fee amount prior to executing the request.
Personal Information Sales Opt-Out and Opt-In Rights (“Do Not Sell”)
If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. QCS has not sold consumers’ personal information in the preceding 12 months for any monetary value and does not intend to sell in the future for any monetary value. However, we could be involved in programs that could be considered a “sale” under the California Consumer Privacy Act, such as in supplying our host utilities with the personal information as part of our agreements with them to provide services to utility customers, which we have done in the past 12 months.
To exercise the right to opt-out of the sale of your personal information, you (or your authorized representative) may submit a request to us by clicking on the “Do Not Sell My Personal Information” button.
Non-Discrimination
We will not discriminate against you for exercising any of your California Consumer Privacy Act rights. Except as provided by our agreements with our host or sponsoring utilities and as permitted by law, QCS will not as a result of you exercising your privacy rights under the California Consumer Privacy Act:
Security
Protecting personal information is a top priority for QCS. We take extensive measures to ensure the integrity of our systems and protect your personal information. We continuously implement and update administrative, technical, and physical security measures to help protect personal information about you from unauthorized access, destruction, or alteration.
Children’s Privacy Online
Children’s privacy is important. We do not have areas of our website intended for use by children. We do not monitor the age of users of the website and do not intentionally collect information from children under the age of 13. If you are under the age of 13, you should not submit personal information on this website or any other website without the consent of your parent or guardian.
Changes to this Privacy Policy
We will review this Privacy Policy when significant changes occur and at least every 12 months. We will notify you of material changes through updates on QCS’s website.
This information is largely taken from similar statements by our host utilities and we wish to acknowledge and thank them for the use of the language used on their website(s).
Contact Us
If you have questions, concerns, or complaints about this Privacy Policy, would like to request a current version, or would like more information regarding our process for updating this Privacy Policy, you can contact us by writing to the following:
QCS Corporate Administration Center
Attn: Privacy Management
4751 East Arrow Highway
Montclair, CA 91763
State Licensed and Insured
License #1034739
ELECTRICAL, HEATING & AC, INSULATION, PLUMBING, ROOFING, WEATHERIZATION
