Privacy Notice

Last modified: September 28, 2023

Introduction

Vanguard Renewables (“Vanguard,” “Company,” “we” or “us”) respects your privacy and is committed to protecting it through our compliance with this privacy notice (“Privacy Notice”).

This Privacy Notice applies to the personal data we obtain from you whether (1) online, including through websites, mobile applications and social media pages that reference this Privacy Notice (“Online Channels”); (2) offline collection in connection with sales, marketing, partner and supplier engagement (“Offline Channels”); and (3) third-party sources.  Online Channels, Offline Channels and third-party sources are referred to collectively in this policy as “Channels”.  This Privacy Notice does not apply to personal data obtained through our Careers website (vanguardrenewables.com/careers), which is subject to the Vanguard Renewables Candidate Privacy Notice, or to products and services that post separate privacy policies.

This Privacy Notice describes the types of personal data we obtain through the Channels, how we may use that personal data, with whom we may share it, and how you may exercise your rights regarding our processing of the information.  The Privacy Notice also describes the measures we take to safeguard the personal data we obtain and how you can contact us about our privacy practices.

The Online Channels may provide links to other third-party websites and features, or contain third-party cookies, that are not owned or controlled by Vanguard.  Please review the privacy policies of these third parties to familiarize yourself with their practices.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it.  

Personal Data We Obtain

We may obtain personal data through the Channels.  The types of personal data we may obtain include:

• Contact information (such as name, phone and fax number, email and postal address) for you or for others (e.g., principals in your business);
• Information used to create online accounts (such as username, password and security question and answer);
• Biographical and demographic information (such as job title/position);
• Financial information (such as payment information, including name, billing address, and payment card details (i.e., card number, expiration date and security code); bank account information; financial statements; income; and credit score);
• Location data (such as data derived from your IP address, country and zip code);
• Contact information you provide about other people you would like us to contact;
• Clickstream data and other information about your online activities (such as information about your devices, browsing actions and usage patterns), including across the Online Channels and third-party websites, that we may obtain through the use of cookies and similar technologies; and
• Other personal data contained in content you submit to us.   This includes information provided in connection with requesting services through the Online Channels, at the time of registering to use portions of our Online Channels, or submitting a request through the “Contact Us” feature of the Online Channels.  We may also ask you for information if you report a problem with the Online Channels.

We use third-party web analytics services in connection with the Online Channels, including Google Analytics, which use cookies and similar technologies to collect data (such as IP addresses) to evaluate use of and interaction with the Online Channels.

We also collect and process other types of information and data which does not constitute personal data.  For example, we may de-identify and aggregate certain personal data we collect such that the information no longer identifies, and cannot any longer reasonably be linked to, a particular user or individual.  We may use this information to improve our services and website, to analyze trends, to create market research, and for other development, marketing, research and statistical purposes, and we may disclose such de-identified information to third parties for these purposes.

Please note that providing personal data to us is voluntary on your part.  If you choose not to provide us certain information, we may not be able to offer you certain products and services, and you may not be able to access certain features of the Online Channels.

Cookies and Similar Technologies

Like most companies, Vanguard uses cookies and similar technologies (“Cookies”) in connection with our websites to personalize and enhance your experience.

Cookies contain small amounts of information which are downloaded to your device when you visit our website.  Cookies are sent back to our website to allow us to recognize your device.  Unless you disable the Cookies on our website, by accessing or using our websites you agree to our use of those Cookies, including to:

• recognize your device to help you navigate efficiently to obtain the information and services you have requested;
• allow our websites to remember your preferences and help you to view information that is most relevant to your interests; and
• help us to maintain and improve our websites by providing information on how visitors find and use the sites, and how well the sites are performing.

If you decide to disable cookies on our websites, you may not be able to take full advantage of all our website features.

How We Use Personal Data

We may use the personal data we obtain to:

• Provide and administer our products and services;
• Process and fulfill orders for products and services and keep you informed about the status of your order;
• Communicate about and administer our products, services, events, programs and promotions (such as by sending alerts, promotional materials, newsletters and other marketing communications);
• Conduct and facilitate surveys, focus groups and market research initiatives;
• Perform data analytics (such as market research, trend analysis, financial analysis and customer segmentation);
• Engage in ad retargeting and evaluate the effectiveness of our marketing efforts (including through our participation in ad networks);
• Provide customer support;
• Process, evaluate and respond to requests, inquiries and applications;
• Create, administer and communicate with you about your account (including any purchases and payments);
• Conduct marketing and sales activities (including generating leads, pursuing marketing prospects, performing market research, determining and managing the effectiveness of our advertising and marketing campaigns and managing our brand);
• Operate, evaluate and improve our business (such as by administering, enhancing and improving our products and services; developing new products, services and Online Channels; managing our communications and customer relationships; and performing accounting, auditing, billing, reconciliation and collection activities);
• Verify your identity and protect against and prevent fraud and other unlawful activity, unauthorized transactions, claims and other liabilities, and manage risk exposure and quality;
• Conduct investigations and comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies and terms (such as this Privacy Notice and other Online Channels terms of use); and
• Maintain and enhance the safety and security of our products, services, Online Channels, network services, information resources and employees.

We may combine personal data we obtain through Online Channels with information we obtain through Offline Channels, as well as other information, for the purposes described above. We may anonymize or aggregate personal data and use it for the purposes described above and for other purposes to the extent permitted by applicable law. We also may use personal data for additional purposes that we identify at the time of collection. We will obtain your consent for these additional uses to the extent required by applicable law.

Data Sharing

We may disclose aggregated information, and information that does not identify any individual, without restriction.   We may disclose personal data that we collect or you provide as described in this Privacy Notice as described below:

• We may share personal data with our subsidiaries and affiliates for the purposes described in this Privacy Notice.  
• We may share personal data with contractors, service providers, and other third parties we use to support our business.  These service providers are contractually required to safeguard the information provided to them and are restricted from using or disclosing such information except as necessary to perform services on our behalf or to comply with legal requirements.
• We may share personal data with our joint marketing partners and other business partners for the purposes described in this Privacy Notice.
• We may disclose personal data  about you (1) if we are required or permitted to do so by applicable law or legal process (such as a court order or subpoena); (2) to law enforcement authorities or other government officials to comply with a legitimate legal request; (3) when we believe disclosure is necessary to prevent physical harm or financial loss; (4) to establish, exercise or defend our legal rights; (5) in connection with an investigation of suspected or actual fraud or illegal activity; or (6) otherwise with your consent.
• We reserve the right to transfer to relevant third parties any information we have about you in the event of a potential or actual sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation) or other business combination. In such case, we will require the relevant third parties to provide comparable levels of protection as Vanguard provides with respect to the information we share.

We do not sell or otherwise disclose personal data about you except as described here or at the time of collection.

Changes to Our Privacy Notice

It is our policy to post any changes we make to our Privacy Notice on this page. If we make material changes to how we treat our users' personal data, we will notify you through a notice on the website home page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically visiting our website and this Privacy Policy to check for any changes.

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at: [email protected].