Notice at Collection for California Residents

Enel North America, Inc.

Purpose and Scope

Under the California Consumer Privacy Act (as amended from time to time, “CCPA”), California consumers are entitled to certain notices and disclosures regarding the collection and use of their personal information. This notice is intended to provide the notice at collection that is required under the CCPA.

Enel North America, Inc. and its affiliates and subsidiaries (collectively, our “Company”) are providing this notice to California residents (“you”) in order to inform you of: (i) the categories of your personal information, including any sensitive personal information, that will or may be collected by our Company and (ii) the purposes for which that personal information will or may be used by our Company.

Personal Information To Be Collected

Categories of Personal Information: The categories of your personal information that will or may be collected by our Company are as follows:

identifiers such as real name, account name, postal address, email address, phone number, date of birth or other similar identifiers;
characteristics of protected classifications under California or federal law such as age, gender and marital status;
visual information, including photographs that we may capture if you attend our events or that you provide to us and video surveillance footage when you visit our locations for the security of our buildings and sites and the safety of our personnel and guests;
physical characteristics or description contained in identification documents such as driver licenses and passports;
audio information captured in recorded calls or any voicemail messages you left with our Company;
commercial information such as signature in agreements entered into with our Company, payment information and transactional history;
financial and tax information such as credit card number, bank account number, debit card number, invoicing information and information for tax form W-9;
internet or other electronic network activity information, such as IP address, cookie data, browsing history and interactions with our websites, applications, systems and emails; and
professional or employment-related information.

Purposes for Collection and Use: Our Company will or may use the personal information identified above for the following purposes:

to communicate with you and respond to your inquiries;
to support any potential or actual business relationship or commercial transaction with you;
to perform the services or provide the products reasonably expected by you if you request those products or services;
to perform or receive services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying your information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services;
to perform marketing activities, such as providing you with marketing materials or information about or related to our Company, inviting you to events and webinars, inviting you to participate in ways to support our Company and entering you in our Company’s prize drawings;
to detect, monitor and protect against any applicable security incidents;
to undertake activities to improve our operations including employee trainings, audit functions and research;
to conduct internal research for technological development and demonstration;
to manage and maintain licenses, permits and authorizations applicable to our Company’s business operations;
to respond to law enforcement requests; and
to exercise our legal rights and comply with applicable law and regulations, including to meet our tax, legal and regulatory obligations.

Sale or Sharing of Personal Information: Other than any personal information collected through cookies or web trackers from your internet activity with our websites (for which you have the right to opt out), our Company will not (i) sell your personal information to a third party or (ii) share your personal information with a third party for cross-context behavioral or targeted advertising.

Sensitive Personal Information to be Collected

Categories of Sensitive Personal Information: The categories of your sensitive personal information that will or may be collected by our Company are: social security number, driver’s license number, state identification card number and/or passport number.

Purposes for Collection and Use: Our Company will or may use the sensitive personal information identified above for the following limited purposes:

to perform the services or provide the products reasonably expected if you request those products or services;
to perform or receive services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying your information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services;
to help ensure security and integrity (to the extent the use of your sensitive personal information is reasonably necessary and proportionate for such purposes);
for short-term, transient use; and
to undertake activities to verify or maintain the quality or safety of a service provided by the Company and to improve, upgrade or enhance our services.

No Sale or Sharing of Sensitive Personal Information: Our Company will not (i) sell your sensitive personal information to a third party or (ii) share your sensitive personal information with a third party for cross-context behavioral or targeted advertising.

Retention Schedule

Our Company retains the personal information and sensitive personal information described above for as long as such information is reasonably needed or permitted to carry out the purposes for which such information was collected. The criteria applied by our Company to determine our retention periods include:

business and commercial purposes for which the personal information is used and the length of time the personal information is reasonably necessary to achieve those purposes;
the length and time we have an ongoing relationship with you;
whether we have a legal obligation to retain the personal information or the personal information is otherwise is reasonably necessary to comply with our legal obligations or contractual commitments (such as certain laws that require us to keep records of your transactions or communications for a certain period before we can delete them);
whether retention is advisable to preserve our legal rights, including to defend against potential legal claims (such as applicable statutes of limitations); and
the way personal information is maintained and flows through our systems and how best to manage the lifecycle of the personal information in light of the volume and complexity of our systems.

Online California Privacy Policy

Our online privacy statement for California residents is available under “California Consumer Privacy Act” at: https://www.enelnorthamerica.com/privacy-policy.

Our Contact Information

For any questions regarding this notice or to request more information, please contact our Company at:

Email Address: dataprotectionoffice-northamerica@enel.com
Toll-Free Phone Number: 1-800-359-6615

Assistance for Disabled Individuals

Alternative formats of this Notice are available upon request to individuals with a disability. For assistance, please contact our Company at:

Email: dataprotectionoffice-northamerica@enel.com
Phone: +1 (800) 359-6615

We may change this Notice from time to time and will indicate the date the last changes were published.

Dated: July 31, 2023