POLICY NO. 100-330

TITLE: PRIVACY POLICY

I. OBJECTIVE
Coos-Curry Electric Cooperative, Inc. (CCEC) is committed to protecting member privacy and providing technology that gives members a safe online experience. This Privacy Policy applies to the CCEC website, mobile applications (App) and member portal, and governs data collection and usage. By using the website, App and/or member portal, members and non-members, as applicable, consent to the data practices described in this policy.

II. GENERAL POLICY


A. Collection of Personally Identifiable Information

1. CCEC collects personally identifiable information, such as e-mail address, name, home or work address or telephone number. CCEC also collects anonymous demographic information, which is not unique to the member, such as zip code, age, gender, preferences, interests, and favorites.

2. CCEC also collects and processes information provided directly by members when they register in the member portal or when they install and register in the App for an account. Specifically, this information includes:

  • Member’s name, email address, location, user’s phone or contact book data, and user’s inventory of installed apps, and user’s screen recording;
  • Browser information and session cookies related to member access and use of the portal and/or App;
  • Data insights based on correlation and analytics of member information collected which may be used in aggregated and dis- aggregated formats or to obtain trend analytics, to provide the portal and/or App; and
  • Use of the above-described collected information in aggregated and dis-aggregated formats to enhance our current portal and/or App or to provide portal and/or App features.


3. CCEC also automatically collects information about computer hardware and software. This information can include: IP address, browser type, domain names, access times and referring website addresses. This information is used by CCEC for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the CCEC website.


4. CCEC may make a chat feature available through its website and/or Apps to assist users. Information provided through the chat feature may be collected, used, and retained by CCEC or its authorized service providers for the purpose of responding to inquiries, providing technical support, maintaining service quality, and improving CCEC services. Users are encouraged not to share sensitive personal or financial information through chat communications unless necessary to fulfill a specific request.


5. Users are encouraged to review the privacy statement of websites they utilize to link to from the CCEC website to understand how those sites collect, use, and share information. CCEC is not responsible for the privacy policies of other websites outside of the CCEC website, member portal and Apps.


B. Use of Member Personally Identifiable Information
1. CCEC collects and uses member personally identifiable information to:

  • Operate the CCEC website and deliver services;
  • Provide members with the portal or Apps as described in this policy;
  • Implement, improve and/or enhance the portal or Apps, including making future releases available to members;
  • ·Carry out CCEC’s obligations as described or authorized in the agreement and this policy;
  • Inform of other products or services available from CCEC and its affiliates;
  • Enforce CCEC’s rights arising from the agreement between a member and CCEC; and
  • Fulfill any other purpose authorized by members and reasonably required for the portal or Apps.

2. CCEC does not sell, rent or lease its members’ personally identifiable information. CCEC may, from time to time, contact members on behalf of external business partners about a particular offering that may be of interest to them. In those cases, personally identifiable information such as member email, name, address and telephone number is not shared with the third party. CCEC may share member information with trusted partners to help perform statistical analysis, send member email or postal mail, provide member support, or arrange for deliveries. All such third parties are prohibited from using member personally identifiable information except to provide these services to CCEC, and they are required to maintain the confidentiality of member information.


3. CCEC may contact members via surveys to conduct research about their opinion of current services or of potential new services that may be offered.


4. CCEC will disclose members’ personally identifiable information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on CCEC; (b) protect and defend the rights or property of CCEC; or, (c) act under exigent circumstances to protect the personal safety of users of CCEC, or the public.


C. Text Messaging Privacy
1. CCEC uses text messaging (SMS and MMS) to communicate with members regarding their electric service and account. Text messages may include account alerts and reminders, billing and payment notifications, planned outage notifications, restoration updates, disconnect notices, public safety information, and other communications related to the delivery of electric service. Standard data and text messaging rates may apply.


2. Certain text messaging programs are available to members who voluntarily enroll through CCEC’s member portal, mobile application, website, or other enrollment methods provided by CCEC. Other operational text messages, including planned outage notifications, restoration updates, disconnect notices, and other service-related communications, may be sent based on a member’s account status or the Cooperative’s operational needs.


3. Members may opt out of receiving applicable text message communications by following the opt-out instructions provided in the text message. Opting out of one text message program does not automatically opt a member out of all text messaging communications or communications necessary for the administration, operations, or safety of electric service.


4. Mobile information will not be shared with third parties or affiliates for marketing or promotional purposes. This includes text messaging originator opt-in data and consent.


5. CCEC may use trusted third-party service providers to facilitate the

delivery of text messages on its behalf. Such service providers may access member mobile information only as necessary to provide text messaging services for CCEC and are contractually required to maintain the confidentiality and security of member information and may not use such information for any other purpose.


D. Use of Cookies
1. CCEC’s website uses “cookies” to help personalize the online experience. A cookie is a text file that is placed on a user’s hard disk by a webpage server. Cookies can be essential or non-essential. Essential cookies are necessary for the function of CCEC’s website. Non-essential cookies are not necessary for the function of CCEC’s website but may enhance a user’s experience while using CCEC’s website. Cookies cannot be used to run programs or deliver viruses. Cookies are uniquely assigned to users and can only be read by a webserver in the domain that issued the cookie to the member.


2. One of the primary purposes of cookies is to provide a convenience feature to save users time. The purpose of the cookies is to tell the webserver that a user has returned to a specific page. This simplifies the process of recording personal information such as billing address, shipping address, and so on.


3. Users have the ability to accept or decline non-essential cookies. Most web browsers automatically accept both essential and non-essential cookies, but users can usually modify their browser setting to decline non-essential cookies if preferred. If a user chooses to decline non-essential cookies, they may not be able to fully experience the interactive features of the CCEC service or websites visited.


E. Security of Member Personally Identifiable Information
CCEC secures member personally identifiable information from unauthorized access, use, or disclosure. CCEC secures the personally identifiable information provided on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. When personal information, such as a credit card number, is transmitted to other websites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.


F. Changes to this Policy
CCEC will review and update this Privacy Policy to reflect federal and state regulations, company requirements, and member feedback.


III. RESPONSIBILITY
The Board of Directors and the GM/CEO shall be responsible for administering this policy.