PRIVACY POLICY/YOUR PRIVACY RIGHTS

Last Updated: February 12, 2018.

INTRODUCTION

Starion Energy Inc. ("Starion" or "us" or "we" or "our") and its affiliates own and operate (or someone on behalf of Starion) the STARIONENERGY.COM site ("Site"). Starion is committed to protecting your privacy when you visit and interact with the Site. As such, Starion's privacy practices are explained in this Privacy Policy ("Policy").

This Policy explains when and how we collect, use, share and safeguard personally identifiable and other information collected through the Site. By using the Site, you agree to the terms of this Policy.

This Policy covers only the Site identified above, and does not apply to information which you may send us by other means. Other Starion sites and other online locations may have their own privacy policies, and you should consult those accordingly.

Standard data and other fees may be charged by your mobile services provider if you access the Site on a mobile device, so please be aware of them.

If you would like more information on the sharing of PII with third parties for direct marketing purposes, please contact us at: Starion Energy, Inc., P.O. Box 845, Middlebury, CT 06762, phone: 800-600-3040, facsimile: 203-262-6001 or email: compliance@starionenergy.com.

POLICY CHANGES

We reserve the right, at our discretion, to modify our privacy practices and update and make changes to this Policy at any time. For this reason, we encourage you to refer to this Policy on an ongoing basis. This Policy is current as of the last updated date at the bottom of this Policy. We will treat PII in a manner consistent with the version of this Policy under which it was collected, unless we have your consent to treat it differently. By using this Site following any Policy change, you freely and specifically give us your consent to collect, treat and/or handle, use, transfer and disclose your PII in the manners specified in such then-current Policy, as modified.

Starion will highlight any changes to this Policy for thirty (30) days after such change(s) is/are made and will be effective when posted. The changes will also be immediately incorporated into this Policy. If any of the changes are unacceptable to you, you should cease using the Site.

COLLECTION AND USE OF INFORMATION

You can generally visit the Site without revealing any personally identifiable information about yourself. Personally identifiable information ("PII") is generally defined as information that may be able to identify you/a natural person or that may be used to get access to your account, including, but not limited to, name or initials, home or other physical address, telephone number, email address or other online contact information, username and password, birthday, credit/debit card number, photograph, age, office address and other business information, biometric data (e.g., fingerprints), state and/or federal identification numbers (e.g., driver's license number; social security number; passport number), etc.

There are areas on the Site where you may be asked to provide Starion with PII, or where such PII or other information may be collected from you in an automated manner.

For example, PII (and other related information such as, but not limited to, zip code) such as name, mailing/physical and/or shipping address(es) (including billing and service addresses), email address, telephone number, current utility account information (including your billing and payment history, energy consumption data, and eligibility information with respect to medical, elderly, disabled, economic development and other incentives), birthday/age, gender, geo-location, username and password, company name, and/or office address and other business information may be collected from you when you:

  • sign up to receive Starion's products or services (the PII for this may come from your utility company);
  • request information on Starion's products or services, and/or request to be contacted about such products and services;
  • sign up for the Starion Rewards program;
  • set up a user account;
  • create a username and password (or security question and answer); and/or
  • participate in surveys, questionnaires, or contests.

In connection with the PII or other information Starion collects from you when you sign up to receive our services, Starion may receive updates from your utility company on some of that PII or other information from time to time throughout our provision of services to you. You may cancel this authorization, to obtain information from your utility, at any time by providing written notice thereof to us or by calling us at 800-600-3040; however, doing so may result in our decision to terminate your service.

We may also obtain information about you from referrals and from directories, websites, and other publicly available sources.

Starion may use your PII and other information to:

  • administer the Starion Rewards program;
  • provide our services to you;
  • provide energy rate comparisons;
  • maintain proper business records and other relevant records;
  • administer your user account;
  • provide ongoing technical support related to your user account;
  • contact you if there are issues with content that you uploaded or posted through the Site;
  • respond to questions, comments and/or requests to be contacted, fulfill your requests, and/or to provide customer service;
  • communicate with you regarding additional uses of your PII beyond the scope of this list;
  • deliver services through the Site;
  • process and catalog responses to surveys or questionnaires;
  • allow you to enter and participate in contests and other promotions, including processing any awards (please see any applicable official rules);
  • send you Starion newsletters and other updates, as well as other information you request;
  • improve the content and general administration of the Site;
  • perform internal Site operations (e.g., fraud prevention);
  • assess software issues and operational problems with the Site;
  • conduct data analysis and testing;
  • monitor Site usage;
  • market and/or advertise other Starion products and services to you;
  • protect your account from fraud, unauthorized access or identity theft and to verify your identity in connection with your account;
  • determine whether we will commence and/or continue to provide you with energy supply service;
  • maintain a record of the purchases you make on the Site and other business records;
  • tailor our products and services to suit your personal interests and the manner in which visitors use our sites, applications and social media assets;
  • analyze trends and statistics regarding visitors' use of the Site and the purchases visitors make on the Site;
  • provide you with administrative information regarding your account(s) with us, such as notification of payments or changes to our terms, conditions and policies;
  • provide you with email updates and announcements concerning our products, services and promotions, including our Starion Rewards Program (if you have registered with us and do not want to be contacted in the future by Starion or our advertising partners, please click the on the unsubscribe link located in such email).
  • allow you to participate on our social networking/media pages;
  • enforce our Website Terms of Use/Legal Notice/Agreement and Terms of Service for Starion products and services;
  • protect our rights, operations and property as well as your rights and the rights of others; and/or
  • for other legitimate business purposes, such as developing new products, improving the Site, determining usage trends and creating marketing campaigns, and as we believe to be necessary or appropriate under applicable law, including to comply with legal process and to respond to government authorities.

Starion may combine the information we collect with publically available information and information we receive from our parent company, affiliated or subsidiary companies, business partners and other third parties. We may use that combined information to enhance and personalize your experience with us, to communicate with you regarding products, services and events that may be of interest to you, for other promotional purposes, and for other purposes described herein.

Starion gathers certain information automatically and stores it in log files. This information includes, without limitation, Internet Protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.

The Site may use other technologies such as cookies (cookies are files that are transmitted to your computer when you visit the Site), pixel tags, web beacons, or other forms of local storage, including HTML5 local storage, in order to collect and track information about visitors to the Site. We may also use cookies and other automated means to identify and authenticate visitors. Information collected from these types of technologies, and from cookies and Flash cookies, is collectively referred to as "Website Usage Data." If you do not want to receive browser cookies, you may be able to set your browser to reject or delete them. If you wish to disable or delete Flash cookies, you should consult the Help file for your Flash application, and/or visit https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html. However, if you turn cookies off (whether browser or Flash cookies), you may not have access to some of the Site's features and services. The other technologies that the Site uses may not be able to be disabled; if you are concerned about this, you should not use the Site. Starion does not use cookies or the other Website Usage Data to collect PII.

Google Analytics

Starion uses a web analytics tool called "Google Analytics" to collect information about use of the Site. Google Analytics collects information such as how often users visit the Site, what pages they visit when they do so, and what other sites they used prior to coming to the Site. We implemented the Demographics Reporting feature that allows us to use cookies to collect information such as the gender of the individual visiting the Site and the age of the individual visiting the Site. We use the information we receive from Google Analytics to improve the Site and other data uses stated herein. Google Analytics collects the IP address assigned to you on the date you visit the Site, rather than your name or other identifying information. Starion does not combine the information collected through the use of Google Analytics with PII. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit the Site, the cookie cannot be used by anyone but Google. Google Analytics' Terms of Use and Google's Privacy Policy restrict Google's ability to use and share information collected by Google Analytics about your visits to the Site. You can prevent Google Analytics from recognizing you on return visits to the Site by disabling cookies on your browser or click here for currently available Google Analytics opt-outs for the web.

SHARING OF PII AND OTHER INFORMATION

Starion may share your PII with our affiliates as well as with applicable utilities and our service providers to assist us with any of the purposes set forth herein (which, for example, might also include disclosures to attorneys, accountants, auditors, credit bureaus, data processors, payment processors, and technical systems consultants) to the extent necessary or appropriate for them to perform their services to us.

Please note that we may release your PII if required to do so by law, a search warrant, a subpoena, a court order or other legal process and/or in cooperation with a governmental or law enforcement investigation. We may disclose your PII if we have a good faith belief that such disclosure is reasonably necessary to detect or prevent fraud or to protect the rights, property, health or personal safety of Starion, our employees, our business partners, our customers, or the public. We may also disclose your PII if you or your legal representative authorizes us to do so, or if it is necessary to collect or report debts owed to us.

Starion reserves the right to transfer any PII in the event we transfer all or a portion of our business or assets, such as in the event of bankruptcy, dissolution, merger or acquisition. However, we will use commercially reasonable efforts to try to require that the transferee use PII in a manner that is consistent with our Policy.

Third Party Websites and Social Networking/Media Websites/Services

As a convenience to our visitors, the Site may contain links to a number of websites and other services that we believe may offer useful information or services. The policies and procedures we described here do not apply to those websites and other services. We suggest contacting those websites and other services directly for information on their privacy, security, data collection, and distribution policies.

Additionally, we may provide you with access to functionality that permits you to post content to your social media account(s). Please note that any information that you provide through use of this functionality is governed by the applicable third party social networking/media website's/service's privacy policy, and not by this Policy. We have no control over, and shall not be responsible for, any third party's use of information that you provide through use of this functionality. Please remember that anything you post on a social networking/media website/service may be visible to the public. This may include the "Like" button or other plugins available through the Site that allow you to share information with persons outside of the Site. Please consult the privacy policies of those third party providers before using them to make sure you are comfortable with the level of sharing.

Starion may also share certain portions of PII and other information with its vendors in order to make the Site and Site-related services function properly. Other than what is referenced herein, the PII and other data collected from you is not shared with nor sold to any person or entity outside of Starion.

RESPONSE TO "DO NOT TRACK" REQUESTS/SIGNALS

Some browsers have a "Do Not Track" feature that lets you tell websites that you do not want to have your online activities tracked. These features are not yet uniform, so we are not currently set up to respond to those signals.

Third parties that may directly collect information through the Site may respond differently than Starion to "do not track" requests, so you should consult the applicable privacy policies of those third parties for that information.

DATA SECURITY AND RETENTION/HOW WE SAFEGUARD YOUR PII

The security of your PII is very important to us. We put in place reasonable physical, electronic, and managerial procedures to safeguard the information we collect.

Only those employees and service providers who need access to your PII in order to perform their duties are authorized to have access to such information. However, we cannot guarantee that all communications between us or information stored on our servers will be free from unauthorized access by third parties such as hackers. Your use of the Site and any Site-related products and services demonstrates your assumption of this risk.

While Starion takes the issue of protecting your PII seriously, you should exercise discretion in what information you disclose and/or transmit to the Site. Starion cannot guarantee that information sent over the Internet is fully secure, and therefore the transmitted information may be intercepted by others before it reaches Starion. If you are concerned about sending information to Starion over the Internet, please send the information by mail or call us to make other arrangements. Starion is not responsible for the security of information sent over the Internet.

Starion retains collected information for a reasonable amount of time in order to fulfill the stated purpose for why the information was collected. Starion will also retain collected information connected to business records for periods of time required by law. If Starion determines that collected information is no longer needed, it will delete such information. Our collection times will be consistent with applicable law.

CHILDREN'S PRIVACY

The Site is intended for individuals 18 years of age and older located in the United States.

The Site is not directed at, marketed to, nor intended for, children under 13 years of age. Starion does not knowingly collect any information, including PII, from children under 13 years of age. If Starion learns that any information was provided through the Site by a person younger than 13 years of age, Starion will delete the information immediately.

Starion will not knowingly use a minor's PII to market or advertise certain products or services deemed harmful to children. Starion also will not knowingly disclose any minor's PII if it has actual knowledge that the minor's PII will be used for the purpose of marketing or advertising the harmful products or services.

NON-U.S. CONCERNS

The Site is meant for individuals within the United States. Starion only knowingly collects information from individuals within the United States. If you provide information to Starion from outside of the United States, you do so at your own risk. If you are outside of the United States, you are responsible for complying with any local laws regarding use of the Site, and related data collection. You also agree and acknowledge that by providing any information, including PII, through the Site, that such information will be transmitted to, and stored in, the United States.

WEBSITE TERMS OF USE/LEGAL NOTICE/AGREEMENT

The Website Terms of Use/Legal Notice/Agreement for the Site is incorporated by reference into this Policy. The Website Terms of Use/Legal Notice/Agreement can be found here.

MISCELLANEOUS

If you have any questions regarding this Policy, please contact Starion at:

Starion Energy, Inc.
P.O. Box 845
Middlebury, CT 06762 USA
Phone: 800-600-3040
Email: compliance@starionenergy.com

It is the policy of Starion to strictly enforce this Policy. If you believe there has been some violation of this Policy, please contact Starion.

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