California Data Privacy Statement

Enel North America, Inc.

Last Updated: July 31, 2023

Pursuant to the California Consumer Privacy Act of 2018 (as amended from time to time, the “CCPA”), this privacy statement provides details regarding the categories of Personal Information about California consumers that Enel North America, Inc. and its subsidiaries, including Enel Green Power North America, Inc. and Enel X North America, Inc. (collectively, “we” or “company”) have collected, used and disclosed in the preceding 12 months.

This privacy statement applies to California residents from or about whom our company obtains Personal Information (collectively, “you” or “your”). This privacy statement does not cover how our company processes the Personal Information of our employees, which is covered through a separate internal statement and notice.

This privacy statement may change from time to time. Please check this privacy statement periodically for updates.

What is Personal Information?

References to “Personal Information” in this privacy statement means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or California household, subject to certain exceptions provided under the CCPA.

Categories of Personal Information Collected

The categories of Personal Information our company has collected about you within the past 12 months 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.
Professional or employment-related information.

Source of Personal Information

Personal Information about you is collected from the following sources:

directly from you;
our service providers, including software vendors, who collect your Personal Information on our behalf or who provide us with your Personal Information; and
publicly available databases and social media platforms.

Purpose for Collecting Personal Information

Personal Information about you is collected by our company 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

Our company does not sell Personal Information, and we have not sold Personal Information of California residents to third parties in the past 12 months, including any Personal Information of minors under 16 years of age. Other than Personal Information collected through cookies or web trackers from a user’s internet activity with our websites (for which California residents have the right to opt out, see also our Cookie Policy), we have not shared Personal Information with third parties for cross-context behavioral or targeted advertising in the past 12 months, including any Personal Information of minors under 16 years of age. As used in this privacy statement, the terms “sell” and “share” have the meanings given to them in the CCPA.

Disclosure of Personal Information

In the past 12 months, the categories of Personal Information about you that our company has disclosed to a third party for a business purpose 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.
Professional or employment-related information.

For each category of Personal Information identified above, the categories of third parties to whom we disclose or may disclose your Personal Information are the following:

our affiliates;
our service providers, including marketing, media and community relations providers, consultants, advisors, providers of software solutions, providers of hosting services, data solution providers, providers of information technology and related infrastructure services, background check vendors and account management and payment processing providers;
financial institutions that support commercial transactions;
government, quasi-government and regulatory agencies and organizations requesting Personal Information with which our company needs to comply; and
third parties, such as acquiring entities and their advisors, in connection with any merger, acquisition, bankruptcy or other transaction in which the third party assumes control of all or part of our company’s business.

Categories of Sensitive Personal Information Collected

In addition, the categories of Sensitive Personal Information (as defined under the CCPA) our company has collected about you within the past 12 months are as follows: social security number, driver’s license number, state identification card number and/or passport number.

Source of Sensitive Personal Information:

Sensitive Personal Information about you is collected from the following sources: (i) directly from you, and (ii) our service providers who collect your Sensitive Personal Information on our behalf or who provide us with your Sensitive Personal Information.

Purpose for Collecting Sensitive Personal Information

Sensitive Personal Information about you is collected by our company for the following limited purpose:

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 does not sell or share Sensitive Personal Information, and we have not sold or shared Sensitive Personal Information of California residents to third parties in the past 12 months, including any Sensitive Personal Information of minors under 16 years of age.

Disclosure of Sensitive Personal Information

In the past 12 months, the categories of Sensitive Personal Information about you that our company has disclosed to a third party for a business purpose are as follows: social security number, driver’s license number, state identification card number and/or passport number.

For each category of Sensitive Personal Information identified above, the categories of third parties to whom we disclose or may disclose your Sensitive Personal Information are the following:

our service providers, including background check vendors and account management and payment processing providers;
financial institutions that support commercial transactions;
government, quasi-government and regulatory agencies and organizations requesting Sensitive Personal Information with which our company needs to comply; and
third parties, such as acquiring entities and their advisors, in connection with any merger, acquisition, bankruptcy or other transaction in which the third party assumes control of all or part of our company’s business.

Your Rights under the CCPA

If you are a California resident, you have the following rights with respect to your Personal Information (including your Sensitive Personal Information), subject to certain exceptions under the CCPA. In certain cases, we may deny your request for reasons permitted by the CCPA.


Right to Know What Personal Information is Being Collected	You have the right to request that our company disclose what Personal Information about you we collect, use or disclose. Specifically, once we receive and confirm your verifiable request (see Exercising Your Rights below), we will at your request disclose to you: Categories of Personal Information we collected about you. Categories of sources from which your Personal Information is collected. Our business or commercial purpose for collecting or sharing your Personal Information. Categories of your Personal Information we disclosed for a business purpose. Categories of third parties to whom your Personal Information was disclosed for a business purpose. Specific pieces of Personal Information we collected about you.
Right to Request Deletion of Personal Information	You have the right to request that we delete any of your Personal Information that we collected from you. Once we receive and confirm your verifiable request (see Exercising Your Rights below), we will delete your Personal Information from our records (and if applicable, notify our service providers and contractors to delete your Personal Information from their records), unless an exception applies under the CCPA. Note that we may deny your deletion request if retaining the Personal Information is reasonably necessary and permitted under the CCPA.
Right to Request Correction	You have the right to request that our company correct inaccurate Personal Information that our company maintains about you.
Right to Opt-Out of Sharing	For Personal Information collected by our company through cookies or web trackers from your internet activity with our websites, you have the right to opt out of us sharing such Personal information with third parties for cross-context behavioral advertising. You can exercise this right through our “Do Not Sell or Share My Personal Information” tool in our cookie banner.
Right of No Retaliation and Discrimination	You have the right exercise your rights under the CCPA free from discrimination and retaliation as prohibited by the CCPA, and our company will not unlawfully discriminate against you for exercising such rights, including but not limited to, by: Denying you products or services. Charging you different prices or rates for products or services, including through granting discounts or other benefits, or imposing penalties. Providing you a different level or quality of products or services. Suggesting that you may receive a different price or rate for products or services or a different level or quality of products or services.

Exercising Your Rights

If you are a California resident, you can exercise these rights by submitting a request to our company by emailing or calling our company at:

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

Exercising Your Rights via Authorized Agent

To submit a request as an authorized agent on behalf of a California resident who wishes to exercise these rights, you may use the same submission methods provided above. As part of our verification process, among other requests we may make, we will request that you provide your contact information, relationship to the California resident, documentation verifying your identity and documentation showing that you are authorized to act as a representative of the California resident (such as a power of attorney or signed written authorization from the California resident).

Verifiable Requests

The CCPA requires our company to verify requests that we receive, and we may ask you to provide certain additional information for our company to verify your request in accordance with the CCPA. To submit a verifiable request, please include in your request:

Description of your request with sufficient detail that allows our company to properly understand, evaluate, and respond to it.
Sufficient information that allows our company to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.

We 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 request does not require you to create an account with us. We will use Personal Information provided in a verifiable request only to verify the requestor’s identity or authority to make the request.

Response Timing and Format

For verifiable requests made by California residents, we will respond to your request in a manner that is consistent with the CCPA. We will endeavour to provide an initial response to your request within 10 business days of receipt and will attempt to fulfil the request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will cover only the 12-month period preceding our receipt of a verifiable request, unless you request a longer period and to the extent such longer period is required under the CCPA. The response we provide 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 readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable request unless it is excessive (in particular because of the repetitive nature of the requests) or manifestly unfounded. If we determine that the request warrants a reasonable fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Do Not Track

Other than as noted here, we do not support “Do Not Track” browser settings at this time. Enel North America’s website supports global privacy controls (“GPC”) that enable do not track functionalities on certain internet browsers when the GPC functionality is enabled by individuals.

California “Shine the Light” Notice

If you are a California resident, you may request information from our company about certain disclosures of your personal information to third parties, as such terms are defined under California’s Shine the Light law (which is a different law with different rights from the CCPA). For more information, please contact us at the Contact Information set out immediately below.

Contact Information

For any questions regarding our company’s privacy policies and practices, please contact us at:

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

Assistance for Disabled Individuals

Alternative formats of this privacy statement 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