Introduction

Solartility Energy Inc. (“Solartility”) is a Canadian-based electricity retailer committed to protecting your privacy. This Privacy Policy describes how we collect, use, disclose, and safeguard your personal information in compliance with applicable laws, including Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA)  and Alberta’s Personal Information Protection Act (PIPA). It also addresses requirements for international operations as we expand globally, and meets the standards set by platforms like Facebook for data use. By using Solartility’s services or website, you agree to the practices described in this Policy. (Effective Date: May 27, 2025)

What Information We Collect

We collect personal information that is necessary to provide our services and run our business. “Personal information” means information about an identifiable individual (this can be anything from contact details to account information). The types of personal information we may collect include:

• Contact Information: Name, mailing address, email address, telephone number, and other contact details.
• Identification and Account Details: Date of birth, account numbers, customer IDs, or other identifiers (for example, if required to verify your identity or set up your account).
• Financial and Credit Information: Credit history or credit score and related information for creditworthiness assessments, as well as payment details such as credit card number or bank account information for billing. This may also include billing address and transaction history with us.
• Service and Usage Information: Data about your electricity services and usage (e.g. energy consumption levels, meter readings, participation in programs like our virtual power plant), and records of your interactions with us (such as customer support inquiries or correspondence).
• Online Usage Data: When you visit our website or use our online services, we collect information such as your IP address, browser type, device identifiers, pages viewed, and how you interact with our site. We also collect data through cookies and similar tracking technologies (described below) to understand website traffic and user behavior.

We will only collect personal information that is necessary for the purposes identified in this Policy or as otherwise permitted by law. If we ever need to collect additional personal information or use it for new purposes, we will obtain your consent where required.

How Information Is Collected

We collect personal information from you in several ways:

• Directly from You: Most information is collected directly from you. For example, when you fill out our online forms or sign-up documents, create an account, enter into an energy service agreement, or communicate with us by phone or email, you provide us with personal details. This includes when you provide contact and payment information during enrollment, or when you update your account information.
• Through Our Website and Apps: We automatically collect certain data when you interact with our website or customer portal. This can include technical information (like IP address and device type) and browsing data via cookies, web beacons, and similar technologies. For instance, if you use our online tools or chat with us on our website, those systems will record usage details. (See Cookies and Tracking Technologies below for more information on what is collected and how.)
• From Third Parties: With your consent, we may collect information from third-party sources. For example, we may obtain credit reports or credit scores from credit bureaus or credit reporting agencies to evaluate your creditworthiness when you sign up for our services. We might also receive updated address or contact information from financial institutions or payment processors when you make payments. If you make payments through our payment service providers, those providers may share confirmation of your payments with us.
• Utility and Service Partners: We receive information related to your energy service from other companies involved in delivering electricity. For instance, we may obtain electricity usage data and meter readings from your local distribution company or metering service in order to bill you and manage your energy supply. We also may receive information from installers or partners if you participate in programs (e.g., solar panel installations or battery storage solutions) that we facilitate.

In all cases, we aim to collect personal information by fair and lawful means. We will inform you of the purposes at the time of collection and will collect from you directly whenever feasible. When we collect information from third parties (such as credit bureaus), it will be done with your knowledge and consent or as authorized by law.

How We Use Your Information

Solartility uses your personal information to provide you with reliable service, to manage our operations, and to fulfill legal requirements. The main purposes for which we use personal information include:

• Providing and Managing Services: We use your information to open and administer your account, supply you with electricity, and deliver any related products or services you have requested. For example, we use your personal details to enroll you as a customer, to schedule installations or service calls, and to manage participation in any Solartility programs (such as green energy plans or virtual power plant membership).
• Billing and Payments: Your information (like contact and financial details) is used for billing you for the energy you consume and any other services. We process payments and conduct transactions using your provided payment information. This includes sending you invoices, processing credit card or bank payments, and maintaining records of your billing history.
• Credit Verification: If applicable, we use the credit-related information you provided or that we obtained (with consent) from credit agencies to assess your creditworthiness. This helps us determine eligibility for services, decide if a security deposit is required, and manage financial risk.
• Customer Service and Communications: We use your contact information to communicate with you about your account and our services. This includes sending service confirmations, notices of rate or plan changes, outage or maintenance alerts, and responding to your inquiries or support requests. We may also use it to provide you with guides or tips on using our services effectively.
• Marketing and Promotions: With your consent where required, we may use your information to inform you about new products, special offers, newsletters, or other opportunities. This could include sending you promotional emails or postal mail about renewable energy products, or targeted advertisements on platforms like Facebook. We may tailor the marketing content you receive based on your account details, location, or usage patterns (for example, offering you solar panel options if you have high consumption). You can opt out of marketing communications at any time (see Your Rights below).
• Analytics and Improvements: We analyze usage data (including website analytics and energy consumption trends) to understand how our services are used and how we can improve them. For instance, we might review website traffic and interactions (via Google Analytics) to enhance user experience, or analyze aggregated customer usage data to develop new energy plans or optimize our virtual power plant operations. Personal information used for analytics is often aggregated or anonymized.
• Security and Fraud Prevention: We may use personal information to protect our customers and business from error, fraud, theft, or damage. For example, we might use identity information to authenticate users accessing accounts, or use monitoring tools to detect suspicious activities on our website.
• Legal and Regulatory Compliance: We use and retain personal information as needed to meet our legal obligations and regulatory requirements. For example, as an energy retailer we must comply with provincial energy regulations and record-keeping rules. We may use your information to fulfill reporting duties to regulators, respond to court orders or lawful information requests, resolve disputes, enforce our contracts (such as our Terms and Conditions), or to defend against legal claims.

We will not use your personal information for purposes other than those identified at the time of collection or as outlined in this Policy, unless we obtain your consent or as required/permitted by law. If we plan to use your information for a new purpose, we will inform you and seek your consent if necessary.

Third-Party Services and Disclosure of Information

Solartility may share your personal information with third parties in certain circumstances, as necessary to provide our services and operate our business. When we disclose information, we do so in accordance with this Policy and all applicable laws, and we limit the information to what the third party needs for the specified purpose. Key third-party relationships include:

• Credit Agencies: If we need to perform a credit check, we share identifying information (such as your name, address, and date of birth) with reputable credit bureaus or credit reporting agencies. They return credit reports or scores to us which we use to make decisions about your account (for example, whether a deposit is required). This process is done with your consent during the sign-up process.
• Payment Processors: We use third-party payment processing companies (for example, credit card processors or banks) to handle customer payments securely. Your payment information (credit card number, bank account, etc.) is transmitted to these processors for authorization and settlement of transactions. These third-party processors are authorized to use your information only as needed to process payments and are contractually obligated to protect your data.
• Service Providers and Partners: We may employ other companies and individuals to perform functions on our behalf. This includes information technology providers (for data hosting, cloud storage, or software support), mailing and printing services (to send out invoices or notices), customer support tools, installation contractors, and other business partners. They may access personal information if needed to perform their functions, but they are not permitted to use it for any other purposes. We require our service providers to safeguard personal information through confidentiality agreements and security measures.
• Analytics Services (Google Analytics): We use Google Analytics (a web analytics service provided by Google) to help us understand how users engage with our website. Google Analytics may set cookies or collect device identifiers and browsing information (such as pages visited, time spent, and interactions). This information is used in aggregate form to analyze website traffic and improve our site design and content. Google may process data outside of Canada (e.g., in the United States) and will use the data only for providing analytics services to us. We do not receive personally identifying information through Google Analytics, only aggregated reports. You can opt out of Google Analytics as described in Cookies and Tracking Technologies below.
• Advertising and Social Media Partners (Facebook Pixel): We use the Facebook Pixel and related Facebook Business Tools to assist with advertising and marketing. The Facebook Pixel is a piece of code on our website that allows us to measure the effectiveness of our ads and to reach people likely to be interested in our services. Through the Pixel, third parties (including Facebook) may use cookies, web beacons, and other storage technologies to collect or receive information from our website and elsewhere on the internet, and use that information to provide measurement services and target ads 3 . For example, if you visit certain pages on our site or perform certain actions (like clicking a plan option), the Pixel will report this to Facebook so that we can later show you a relevant Solartility ad on Facebook or to measure if an ad led you to our site. The information shared with Facebook through the Pixel does not include your name or direct contact information, but it may include data like your IP address, device or browser info, and the actions you took on our site. Facebook can combine this data with your user account on their platform to tailor ads, under the terms of Facebook’s privacy policy. We do not share sensitive personal information (such as credit or financial details) with Facebook.
• Legal and Regulatory Disclosure: We may disclose personal information to governmental authorities or other third parties if required to do so by law or pursuant to legal process. For instance, we could be required to share information in response to a subpoena, court order, or regulatory audit. We may also disclose information to our legal counsel or advisors in order to obtain advice, or in the event of a merger, acquisition, or financing deal (in which case the receiving party would be required to keep the information confidential).

Whenever we share personal information with a third party, we make efforts to ensure they have appropriate privacy and security standards in place. We do not sell or rent your personal information to third-party marketers. Any third parties that process personal information on our behalf must adhere to contractual limits and obligations that are consistent with this Privacy Policy and Canadian privacy laws.

Cookies and Tracking Technologies

Like most websites, our site uses cookies and similar tracking technologies to enhance your experience, analyze usage, and support our marketing. Cookies are small text files placed on your device when you visit a website. We use the following types of cookies and tracking tools on our site:

• Necessary Cookies: These are essential for the operation of our site and enable core functionality (for example, keeping you logged in to the customer portal or remembering items in your application form). Without these cookies, certain services or features may not be available.
• Analytics Cookies: We use analytics cookies (such as those from Google Analytics) to collect information about how visitors use our site. This data (e.g. which pages are visited, how long users stay, how they navigate) helps us improve website design, performance, and content. The analytics cookies may collect your IP address or device ID, but they do not directly identify you by name. We configure Google Analytics to anonymize IP addresses where applicable.
• Advertising Cookies/Pixels: We use advertising cookies and pixels to deliver tailored ads and measure their performance. In particular, the Facebook Pixel on our site sets a cookie (_fbp) and uses similar technologies to track when you take certain actions on our website after interacting with our Facebook ads. This allows us to show you relevant advertising on Facebook and partner sites, and to know which advertisements are effective. These tracking technologies might also be used in the future for other ad platforms as we expand our marketing. Advertising cookies collect information such as the pages you visited, whether you completed a signup, or other interactions, and they send this data to the respective platform (e.g., Facebook). This helps create what are called “interestbased” or “retargeted” ads.

When you first visit our website, you may see a banner or notice about cookies if required. By using our site after seeing that notice, or by continuing to use our site, you signify your consent to the placement of cookies as described (where your consent is required by law). You can choose to disable or delete cookies through your browser settings. Most browsers allow you to refuse new cookies, get notified when you receive a new cookie, or delete existing cookies. Please note that if you disable certain cookies, some features of our site (especially the portal or interactive tools) may not function properly.

Online Tracking and Opt-Out: We honor any specific consent requirements that apply to cookies and online tracking in different jurisdictions. If you wish to opt out of analytics and advertising tracking:

• You can install the Google Analytics Opt-out Browser Add-on which prevents Google Analytics from using your data from our site.
• For the Facebook Pixel and other interest-based advertising, you can use industry opt-out tools. For example, the Digital Advertising Alliance provides an opt-out tool at aboutads.info (for U.S.based choices) and youradchoices.ca (for Canadian users) that allows you to opt out of targeted ads from participating companies. Using these tools can set cookies in your browser to signal your preference not to be tracked by certain third parties.
• You can also adjust your advertising preferences directly on platforms like Facebook (for instance, in Facebook’s settings, you can manage your “Ad Preferences” to control how your data is used for ads). Facebook also honors the choices of users who have enabled a global privacy control or who use browser tracking protection features.

Please note that even if you opt out of targeted advertising, you may still see Solartility advertisements online, but they will be generic and not based on your web activity. Also, our site does not respond to “Do Not Track” signals from web browsers, but the methods described above are effective ways to control tracking.

User Consent and Access to Information

Consent for Collection and Use: Solartility collects and uses your personal information with your consent, except where otherwise permitted or required by law. In most cases, your consent is obtained explicitly – for example, by agreeing to the terms of this Privacy Policy (such as when you sign up for our services or check a consent box on a form). In some cases, your consent may be implied by your actions. For instance, when you voluntarily provide us with personal information (like filling out an online form or sending us an email inquiry), we interpret that as consent to use the information to respond to you or provide the service requested. Similarly, by continuing to use our website, you consent to the collection of certain online data as explained in this Policy. We will seek express consent for any collection or use of personal information that is sensitive or outside the reasonable scope of our relationship. For example, before performing a credit check, we will explicitly ask for your agreement. You have the right to refuse or withdraw consent at any time (subject to legal or contractual restrictions) – see Your Rights below for more on withdrawing consent.

Accessing and Correcting Your Information: You have the right to request access to the personal information we hold about you 4 . This means you can ask us to provide you with: (a) a confirmation of whether we have personal information about you, (b) a summary of what that information is, (c) an explanation of how we have used or are using it, and (d) a list of any third parties to whom it has been disclosed. You may make an access request by contacting us (see Contact Information at the end of this Policy). We will need to verify your identity before releasing personal data to ensure we don’t give it to the wrong person. We will respond to access requests as soon as reasonably possible and, in any event, within the time frame required by law (typically within 30 days). We will provide the information at no cost to you, aside from possibly a minimal fee in rare cases as allowed by law (but we will inform you of any charge in advance). If we cannot give you certain information (for example, if it involves someone else’s personal data or other confidential/proprietary information), we will explain why, subject to any legal restrictions.

We strive to keep your personal information accurate and up-to-date. If you believe that any information we have about you is incorrect or incomplete, you have the right to request a correction or update. Upon receiving a correction request, we will correct the information as required. If we decide not to make the requested change (for instance, if we disagree that the information is wrong), we will note your request in the record and let you know the reason. Where appropriate, if we have disclosed the incorrect information to a third party (for example, a credit bureau or partner), we will also notify them of the correction.

Storage and Protection of Personal Information

Storage Location: We primarily store personal information on secure servers located in Canada. However, we also use reputable cloud service providers and technological solutions that may involve data storage or processing in other countries (for example, if we use a cloud email service or an analytics service that operates from the United States or Europe). Regardless of where data is stored, we take steps to ensure it remains protected and that any service providers are bound to maintain privacy protections equivalent to those in Canada. (See International Data Transfers below for more about data in other jurisdictions.)

Safeguards: Solartility employs a variety of security measures to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, or modification 5 . We use administrative, technical, and physical safeguards appropriate to the sensitivity of the information. These include: restricting access to personal data only to staff or contractors who need to know it to perform their duties; maintaining up-to-date security software and encryption technologies; firewalls and network protection to prevent intrusion; secure data centers with access controls; and staff training on privacy and data security. For example, financial information like credit card numbers is encrypted and transmitted over secure connections, and stored in encrypted form by our payment processors. Paper records (if any) containing personal information are kept in locked cabinets or secure facilities. We also require any third-party service providers handling personal information on our behalf to implement robust security measures.

Despite our best efforts, no security measure is absolutely foolproof. However, we regularly review our security practices to update them in line with best practices and to address new threats. In the unlikely event of a data breach that poses a real risk of significant harm to you, we will notify you and the appropriate authorities as required by law.

Retention Period: We retain personal information only as long as necessary to fulfill the purposes for which it was collected, or as required or permitted by law. The length of time we keep your data will vary depending on the nature of the information and the purpose. For example, we keep your account and billing information for as long as you are our customer, and for a certain period after (to answer questions, resolve issues, or meet legal retention requirements). Customer transaction records may be retained for a number of years to comply with tax and energy regulations. If you apply for service but do not become a customer, we may keep the information for a shorter period in case you decide to enroll later, but we will delete it or anonymize it in accordance with our internal retention schedules. When personal information is no longer needed for its intended purpose or required by law, we will securely destroy, erase, or anonymize it. For example, paper documents may be shredded and electronic files securely deleted or wiped from systems.

International Data Transfers

As Solartility grows and potentially offers services in countries outside of Canada, we want to be transparent about how personal information might be transferred or accessed internationally. Currently, the core of our operations is in Canada, but some of our service providers (such as cloud hosting, email, or analytics providers) may process or store data in other jurisdictions (such as the United States). In the future, if we expand to other countries or have customers from other regions, we may need to transfer personal information across borders to serve those customers or to operate global systems.

Whenever personal information is transferred outside of Canada, it will remain subject to adequate protections. We will ensure that recipients of the information (e.g., service providers or Solartility affiliates in other countries) are bound by confidentiality and robust privacy obligations. For example, we may use standard contractual data protection clauses or other legally recognized transfer mechanisms to ensure that personal data is safeguarded in accordance with this Policy and Canadian standards, even when it is processed in a foreign jurisdiction.

It’s important to note that personal information stored or processed in another country may become subject to the laws of that country and accessible to its government, courts, or law enforcement agencies.

For instance, data stored in the United States might be lawfully accessed by U.S. authorities under that country’s laws. Similarly, if we have operations in the European Union or elsewhere, local data protection laws will apply to those activities. Regardless of where processing occurs, Solartility will continue to treat your personal information in line with the commitments of this Privacy Policy. We remain accountable for the personal information under our control, including when it is handled by third parties or offices in other jurisdictions.

If you have questions about our use of service providers outside of Canada or require further information about our policies and practices regarding international data transfers, you can contact us and we will provide more detail. Our goal is to be transparent and provide you with assurance that your privacy is protected, no matter where your data is processed.

Your Rights

Under PIPEDA, Alberta’s PIPA, and other applicable privacy laws, you have several important rights regarding your personal information. We are committed to upholding these rights and enabling you to exercise them. Your rights include:

• Right to Be Informed: You have the right to know why we are collecting your personal information, how it will be used, and who it will be shared with. We address these points in this Privacy Policy and will inform you at the time of collection about the purposes of data collection. If you have any questions about our data practices, you can always contact us for more information.
• Right of Access: You have the right to request access to the personal information we have about you 4 . This means you can ask for a copy of, or information about, the personal data in our records, as well as an explanation of how that information has been used and who it has been disclosed to. (See the User Consent and Access section above for details on how to make an access request.) We will provide an accessible format of your information, generally at no charge, within the legally required time frame.
• Right of Correction (Rectification): If any of your personal information with us is inaccurate or incomplete, you have the right to request that we correct or update it 7 . We encourage you to keep your information up to date and will gladly make corrections to ensure accuracy. For example, if your contact information or billing details change, you can notify us and we will update our records. If we have shared incorrect information with third parties (like a credit bureau), we will also communicate the correction to them where appropriate.
• Right to Withdraw Consent: Where our processing of your personal information is based on your consent, you have the right to withdraw that consent at any time 8 . This includes cases where you previously agreed to a specific use of information (for example, receiving marketing emails or undergoing a credit check) and have since changed your mind. You can contact us to withdraw consent, and we will explain any consequences of doing so. In general, withdrawing consent will not affect services that do not rely on that consent. However, for certain services, if you withdraw consent for us to use essential information, we may not be able to continue providing you with that service. (For instance, if you withdraw consent for us to use your billing information, we might not be able to process payments.) We will inform you if such a situation arises. Outside of the consent context, you may also have a right to object to certain types of processing or to request deletion of information in some jurisdictions – we will accommodate such requests if required by applicable law.
• Right to Privacy and Complaint: We take your privacy rights seriously. If you have concerns or complaints about how we handle your personal information, you have the right to raise those concerns. We encourage you to contact us first so we can address the issue directly. We will investigate and respond to any privacy complaints or inquiries you submit. If you are not satisfied with our response or believe we are not complying with our legal obligations, you have the right to file a complaint with the relevant privacy regulator. For Canadian customers, this may be the Office of the Privacy Commissioner of Canada (for PIPEDA matters) or the Office of the Information and Privacy Commissioner of Alberta (for PIPA matters). The federal Privacy Commissioner’s office can be contacted if you wish to lodge a formal complaint about our privacy practices 9 . We will provide you with their contact information upon request, or you can find it on the Privacy Commissioner’s website.

Exercising Your Rights: To exercise any of your rights (access, correction, withdrawal of consent, etc.), please contact us using the information in the Contact Information section below. We may need to verify your identity before fulfilling certain requests to ensure we are protecting your information from unauthorized access. For example, if you are asking for access to your data, we might need to validate that you are the account holder or their authorized representative. We will respond to your requests within the timelines required by law and will let you know if we need more information from you to process your request.

Please note that some rights may not apply in all circumstances. For instance, in certain situations we might not be able to delete data that we are required to keep for legal reasons, or we might decline a request to access information if doing so would reveal personal data about another individual. We will always explain our reasoning if we cannot fulfill a request in full. Our commitment is to transparency and fairness in addressing your rights.

Changes to This Policy

We may update or revise this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or for other operational reasons. When we make changes, we will update the “Last Updated” or “Effective Date” at the top of the Policy. If any changes are material (significant), we will take reasonable steps to inform you, such as by posting a prominent notice on our website or, if appropriate, contacting you through email or postal mail. For example, if we were to change how we use your personal information or start collecting new types of data that could impact your privacy, we would let you know in advance and obtain your consent if required.

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. Your continued use of our services or website after any update to the Policy will be taken as acceptance of the terms of the revised Policy, to the extent permitted by law. However, we will not use your personal information in new ways without first providing you an opportunity to consent (if required).

In summary, we will always keep our Privacy Policy up to date with our practices and legal obligations, and we will notify you of significant changes and obtain consent where necessary. This Policy is a living document that grows and changes as Solartility and the privacy landscape evolve.

Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal information, please contact us. We are here to help and address any issues you might have.

Privacy Officer – Solartility Energy Inc.

Email: info@mail.solartility.ca

Mailing Address: Privacy Officer, Solartility Energy Inc., PO BOX 442 STN CENTRAL CALGARY AB T2P 2J1, Canada.

Telephone: +1 (877) 521-1994 (toll-free) – Please ask to speak with the Privacy Officer or a management representative responsible for privacy.

When you contact us, please provide your name and contact information and clearly describe your question or request related to privacy. If you are making a request to access or correct your information, details of what you need will help us fulfill your request efficiently. We will respond as promptly as possible, generally within 30 days.

Thank you for reviewing Solartility’s Privacy Policy. We value your trust and are dedicated to safeguarding your personal information and privacy rights.