Last Updated and Effective Date: July 1, 2024
3Degrees Group, Inc., and its subsidiaries (collectively “3Degrees”) Privacy Policy
- Introduction. Your privacy is important to 3Degrees Group, Inc. (“3Degrees“, “we“, “us” or “our“). This Privacy Policy discloses the data processing and privacy practices followed by 3Degrees with respect to your Personal Data collected by 3Degrees through its public website, employment website, media form, media channel, mobile site, or mobile application (collectively, the “Site“). This includes the type of information that we gather, the way we use information and our policy regarding disclosing information with others. We encourage you to read this Privacy Policy.
- Definitions
- “Personal Data” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. “Personal Data” does not include: (i) publicly available information or lawfully obtained, truthful information that is a matter of public concern; or (ii) information that is deidentified or aggregated consumer information.
- “Sensitive Personal Data” means Personal Data that reveals information such as: (a) social security, driver’s license, state identification card, or passport number; (b) account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (c) precise geolocation; (d) racial or ethnic origin, religious or philosophical beliefs, or union membership; (e) the contents of a consumer’s mail, email, and text messages unless we are the intended recipient of the communication; and (f) genetic data. Sensitive Personal Data includes: (x) biometric information processed for the purpose of uniquely identifying a consumer, (y) Personal Data collected and analyzed concerning a consumer’s mental or physical health and (z) Personal Data collected and analyzed concerning a consumer’s sex life or sexual orientation. Sensitive Personal Data that is publicly available is not considered Sensitive Personal Data or Personal Data.
- Categories of Personal Data We Collect. 3Degrees may collect the following categories of Personal Data:
- Identifiers, including your name, email address, telephone number, business contact information and title, postal address, utility account number, driver’s license number, state identification number, social security number, and passport number, your internet protocol (IP) address, and other information regarding your interaction with an internet website, application, or advertisement.
- Commercial Information, including information related to general energy usage patterns.
- Internet or Other Network Activity Information, such as your internet protocol (IP) address, your browsing history, the pages you have visited (including the domain names from which visits to our Site originate), your settings and preferences each time you visit our Site and other information regarding your interaction with our Site (including all actions that are initiated or facilitated using our Site). We also maintain a log file of all actions that are initiated or facilitated using our Site, to capture, record and store data concerning the transaction.
- Geolocation Data, such as your IP address or, for example, information regarding where and where you have charged an electronic vehicle.
- Professional or Employment-Related Information, such as your employment background, prior positions, business contact information and job title.
- Inferences Drawn from Personal Data. We may use your data to produce and disclose aggregated insights that do not identify you.
- Financial/Account Information, such as your credit card information and bank transfer details.
- Why We Collect Your Personal Data. We collect your Personal Data for the following business purposes:
- To deliver or facilitate the delivery of products or services.
- To provide you with special offers, product information and other marketing or promotional communications from 3Degrees or from other third parties.
- For marketing purposes and to inform those interested in our products about events, products, services or other items of interest.
- To register you for an extranet account or to process orders for brochures and other written materials.
- To send periodic mailings or make telephone calls to visitors who have provided a mailing address or telephone number of new products, services, or events.
- To help us measure and understand how our Site is being used and improve your user experience, including by improving the content or responsiveness of our Site, customizing the content or layout of the site for the individual visitor, recognizing prior users to the site, keeping you logged into the Site, and facilitating purchase procedures.
- To help identify and prevent security risks, to authenticate users and protect user data from unauthorized parties.
- To generate statistics, to calculate ad impressions served or clicked on, or to publish visitor insights.
- In the event of a dispute, in response to legal process or law enforcement inquiries, abuse of our Site, or violation of our Privacy Policy.
- To facilitate your purchase of goods and services through the 3Degrees marketplace.
- To verify your identity and facilitate your use of the services made available through the 3Degrees portal:
- For order processing, including billing and payment;
- For asset recovery and product returns and replacements;
- For contract performance and solution delivery;
- To manage job applications
- Further information of the data we collect:
- Subject to the disclosures made above, set forth below in chart format are the categories of Personal Data we collect and the purpose for the collection.
| Category of Personal Data | Purpose for the Collection |
| Identifiers | See Sections 4a-4l |
| Commercial information | See Sections 4a-4l |
| Internet or Other Electronic Network Activity Information | See Sections 4f-4h |
| Geolocation Data | See Sections 4f-4h |
| Professional or Employment-Related Information | See Sections 4a-4l |
| Inferences | See Section 4a-4l |
| Financial/Account Information | See Section 4a-4c, 4j, 4k |
- Sale and Sharing of Personal Data.
- Except as noted below, 3Degrees never sells your Personal Data, nor do we employ any financial incentives related to the retention or sale of Personal Data. Any information that you provide to us will be used only for purposes related to 3Degrees or the client on whose behalf we are collecting it.
- Under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2023, and related regulations (the “CPRA”), our use of third-party cookies, analytics, ad providers and other disclosures, described herein, may be deemed to constitute a sale.
- Sharing of Personal Data for Cross-Context Behavioral Advertising (Targeted Advertising. To provide you with special offers, product information and other marketing or promotional communications from 3Degrees or from other third parties, we may use targeted ads both on our digital properties as well as others, directly or through a variety of partners using the following Personal Data:
- Personal Data from advertising technologies on and off our services like web beacons, pixels, ad tags, cookies, and device identifiers.
- Personal Data you provide to us via our Site or to 3Degrees (for example, account-related information such as name and address).
- Personal Data obtained from your use of our services (for example, activity-related information such as search history, feed, content you read, page visits, videos you watch, or clicking on an ad).
- Information from advertising partners and publishers.
- Third Party Advertisers. We do not share your Personal Data with any third party advertisers or ad networks for their advertising except: (i) hashed (encrypted) identifiers or device identifiers (to the extent they are Personal Data in some countries); or (ii) with your separate permission (e.g., provided via a lead generation form). However, if you view or click on an ad on or off our Site, the ad provider will get a signal that someone visited the page that displayed the ad, and they may identify you through the use of mechanisms such as cookies. Advertising partners can associate Personal Data collected by the advertiser directly from you with our cookies and similar technologies. In such instances, we seek to contractually require such advertising partners to obtain your explicit, opt-in consent before doing so.
- Third Party Tracking. In addition, as discussed above, we use third-party cookies and third-party tracking tools on our Site to measure traffic to our Site and how users interact with our Site and for targeted advertising. This may be considered a sale or sharing under the CPRA. In addition, we use third-party analytics providers to generate reports for us regarding how users reach the Site, how they interact with and move around once on the Site, what features on the Site are working the best, and what features on the Site can be improved. To find out more about how our analytics providers use data when you use our Site and your options for controlling the information collected on the Site, including your right to opt-out of having your activity made available to our providers, please click on the “Cookie Management” button in the footer of our Site to modify your preferences.
- Aggregate Insights. We may use your Personal Data to produce and disclose aggregated insights that do not identify you. For example, we may use your Personal Data to generate statistics, to calculate ad impressions served or clicked on, or to publish visitor insights. We may also aggregate anonymized information relating to our visitors’ traffic patterns from the data that we collect and retain concerning the IP addresses and domain names of our visitors, and we may use or divulge such aggregate information about our users with third parties such as our business partners, distributors, and service and support providers. You may visit our Site anonymously if you wish, by using appropriate software or web services available from third parties.
- Further Information on Our Disclosure Practices. Subject to the disclosures made above, set forth below in chart format are the categories of Personal Data we collect and the purpose for the collection. Personal Data may be disclosed in the following ways:
- Within 3Degrees and any of our worldwide subsidiaries for the purposes of data processing, such as marketing, business operations, security, or functionality.
- With business partners, vendors, authorized third-party agents, or contractors to provide an action. This could include processing of orders, hosting websites, assisting with sales efforts, and providing customer support.
- With 3Degrees business partners or vendors, so that they may share information with you about their products or services.
- To opt out of 3Degrees sharing with third parties for their marketing purposes, please submit a request following the instructions in the “Contact Us” section.
- In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business.
- In response to a request for information by a competent authority or third party if we believe disclosure is in accordance with any applicable law or regulation.
- With law enforcement officials, government authorities, or other third parties as necessary to comply with legal process or meet national security requirements; protect the rights, property, or safety of 3Degrees.
- We may also disclose your Personal Data to our service providers and contractors for the following business purposes:
- Security and Fraud Detection. We disclose Personal Data for our security and fraud detection services including detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity; and prosecuting those responsible for that activity.
- Functionality & Debugging. We disclose Personal Data to engage in debugging to identify and repair errors that impair existing intended functionality of the Site or our other technological services.
- Short-Term/Transient Use. We disclose Personal Data for short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your interaction with us. Your Personal Data is not sold or shared with a third party for cross-context behavioral advertising, is not used to build a profile about you and does not otherwise alter your experience outside the current interaction with us.
- Services on Our Behalf. We disclose Personal Data in order to receive services performed on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on our behalf. We may need to provide your name and delivery address to third parties that we use for delivering our products or services to you (such as support services, shipping, direct mail organizations, research, or analytics).
- Advertising and Marketing Services. We may disclose Personal Data to provide certain advertising and marketing services to you.
- Research & Development. We disclose Personal Data for conducting internal research related to our technological development and demonstration.
- Quality Control & Improvement of Products and Services. We disclose Personal Data for verifying or maintaining the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and improving, upgrading, or enhancing the service or device that is owned, manufactured, manufactured for, or controlled by us.
- If we otherwise notify you and you consent to the sharing.
- We may also disclose Personal Data, as necessary in the event of a dispute, in response to legal process or law enforcement inquiries, abuse of our Site, or violation of our Privacy Policy.
- We will retain each category of your Personal Data identified above for an amount of time that is reasonably necessary for us to use the information for the purposes disclosed herein and for any other permitted purposes, including retention of Personal Data pursuant to any applicable contract, law or regulation. Your Personal Data may also be retained or deleted according to contractual or other legal requirement, or at your request
- To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
- We use cookies and other similar technologies (collectively “cookies”) to provide our services, to understand how they are utilized, and for analytics, personalization, and marketing purposes. You can read more about the types of cookies we (3Degrees and our third-party service providers) use, why we use them, and how you can exercise your cookie choices below. For example, we use HTTP cookies (web/browser cookies), which are small data files that are downloaded when you access our services and allow us to recognize your device. Cookies can be necessary and useful in a number of ways. For example, cookies enable websites to recognize your device and are often used to help the website function properly and to provide necessary and useful information to us. Cookies are necessary to recognize or “remember” visitors.
- How can you exercise your choices? You have the right to choose not to accept certain cookies, but please note that even optional cookies are an important part of how our sites work, so you should be aware that if you choose to remove certain cookies, it could affect the functionality of our services. You can also change your preferences in relation to how this website uses cookies by clicking on “Cookie Management” button in the footer of our Site.
- Personal Data gathered about customers interested in our products and services is only accessible by appropriate personnel who have a business need for the information. 3Degrees provides training and communication programs to educate its personnel about the meaning and requirements of this privacy policy. It uses systems, policies and procedures to maintain the accuracy of customer information and to protect it from loss, misuse, or alteration.
- Encryption. The connection to this site is encrypted and authenticated using TLS 1.2 and 1.3 (a strong protocol), 2048-bit key (a strong key length), and SHA-256 (a strong hash).
- We safeguard the security of the data you send us using physical, electronic, and managerial procedures. We have taken reasonable precautions to protect against misuse, theft, loss, unauthorized access, disclosure, alteration or destruction of your Personal Data. While we strive to protect your Personal Data, we cannot ensure the security of your information prior to our receiving it, and so we urge you to take every precaution to protect your Personal Data when you are on the Internet. We suggest that you change your passwords often, that your passwords include a combination of upper and lowercase letters, numbers, and symbols and that you make certain that you are using a secure browser. Products and services are available which can help give you privacy protection while navigating the internet.
- Email Communication. You should know that email is not necessarily secure against all forms of interception. If your communication includes sensitive information about you and you would prefer not to transmit this information in this fashion, please contact us by mail or telephone rather than email.
- Right to Know Personal Data Collected About You. You have the right to know: (1) the categories of Personal Data we have collected about you; (2) the categories of sources from which the Personal Data is collected; (3) the business or commercial purpose for collecting, selling, or sharing Personal Data; (4) the categories of third parties to whom we disclose Personal Data; and (5) the specific pieces of Personal Data we have collected about you. You also have the right to know the list of all third parties to whom we have disclosed Personal Data, as defined under California Civil Code Section 1798.83 (a/k/a the “Shine the Light Law”) as well as other applicable laws, during the preceding year for third-party direct marketing purposes. You may submit a request by submitting this form.
- Right to Know Personal Data Disclosed, Sold or Shared. You have the right to request that we disclose to you: (1) the categories of Personal Data that we collected about you; (2) the categories of Personal Data that we sold or shared about you and the categories of third parties to whom the Personal Data was sold or shared, by category or categories of Personal Data for each category of third parties to whom the Personal Data was sold or shared; and (3) the categories of Personal Data that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
- Right to Request Deletion of Your Personal Data. You have the right to request that we delete your Personal Data, subject to a number of exceptions. Following receipt of a request, we will let you know what, if any, Personal Data we can delete from our records. If we cannot delete all of your Personal Data, we will let you know the reason.
- Right to Correct Inaccurate Information. If you believe that any of the Personal Data we maintain about you is inaccurate, you have the right to submit a request for us to correct that information. Upon receipt of a request, we will use commercially reasonable efforts to correct the information as you direct.
- Right to Opt-Out of the Sale and Sharing of Your Personal Data. You may opt-out of the sale or sharing of your Personal Data, to the extent applicable, by clicking on the “Cookie Management” button in the footer of our Site to modify your preference or going to the “Contact Us” section.
- Right to Limit the Use of Your Sensitive Personal Data. California residents have the right to limit the use of Sensitive Personal Data under certain circumstances. You do not have this right where we use your Sensitive Personal Data for any of the following purposes: (i) when it is necessary to perform the services or provide the goods reasonably expected by you; (ii) to help to ensure security and integrity; (iii) to perform services on our behalf; (iv) to undertake activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us; and (v) to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us. You can exercise this right by clicking on “Cookie Management” button in the footer of the Site or going to the “Contact Us” section.
- Right to Non-Discrimination for Exercising Your Rights. If you choose to exercise any of your rights, you have the right to not receive discriminatory treatment from us.
- When you make a request to know, delete and/or correct, to help protect your privacy and maintain security, we will take steps to verify your identity, within our sole discretion and as permitted by applicable laws. Our verification procedure may differ depending on whether or not you have an account with us and the request you are making.
- When 3Degrees is acting as a “data controller,” you can exercise your privacy rights as described in this section.
- When 3Degrees is acting as a “data processor,” and you wish to exercise your privacy rights of access and request corrections, suppression, or deletion, 3Degrees will direct you to the data controller under the applicable data protection laws.
- We will respond to requests to know, requests to delete no later than 30 calendar days. If we cannot verify your request within 30 days, we may deny your request. If necessary, we may take up to an additional 30 days to respond to your request but in such an event will provide you a notice and an explanation of the reason that we will take more than 30 days to respond to your request.