CCPA Privacy Notice

THE CCPA AND YOUR PERSONAL DATA RIGHTS
The California Consumer Privacy Act (CCPA) grants California residents increased control over their personal data.

This CCPA privacy notice provides the details you need to understand your rights under the CCPA, and to exercise those rights. It also provides you with the contact information you need to take action regarding the privacy of your data.

Defining Personally Identifiable Information
Various laws and regulations (including the CCPA) use different terms and definitions for information about individuals that is personal and should be protected. Some laws and regulations consider only very limited types of information to be protected and private. Others include much broader categories.

At Energy Capital Partners, we have chosen to adopt the broader approach to what information must be protected and kept as private as possible. In this notice, “Personally Identifiable Information” (PII) refers to data that could be used, alone or in combination with other data, to identify you as an individual. It can include name, physical address, email address, IP address, date of birth, social security number, passwords, and more.

Types of Collected PII
Energy Capital Partners collects some of your personally identifiable information. This section describes the categories of PII that are collected, as well as the categories of sources for obtaining that PII, and the purpose for collecting it.

PII Categories
The PII we collect from you may consist of the following categories:

Contact Information
• Full Name
• Home and/or Business address
• Email Address
• Telephone number

Other Identifying Information:
• Date of Birth,
• Social Security Number
• Tax ID
• Driver’s license number
• Passport number

Banking Information
• Account numbers
• Wire instructions

Employment information
• Including information gathered for purposes of securing at-will employment at ECP
- Background checks of education and former employers
- Credit reports
- Civil/Criminal activity reports

Such categories of information are provided for illustrative purposes only. ECP does not collect all of the specific PII provided as examples above.

Sources for PII
The categories of sources of the PII we collect about you are: Information you provided to us;
Information provided by third parties or publicly available sources

Purpose for Collecting Your PII
We collect your PII for a variety of reasonable business purposes including:
• Facilitating financial transactions related to your desired investment
• Creating and managing your account with us
• Contacting you or your designated representative by phone, email, fax, or mail
• Providing you or your representative with marketing communications
• Sharing information about our services including investment research
• Fulfilling our legal and regulatory obligations
• Managing job applications and employment at ECP

*Our Website and Your PII *
Visiting and navigating our website will likely involve some form of usage of your PII. This section details the methods and permissions involved.

Consent to Use Your PII
By visiting our website or providing information when using our contact email, you consent to our storing and using your PII for the reasons provided in this notice. You also consent to our using it to reply to your request as well as to contact you in the future, whether or not at your request, to provide you with additional information.

Note that we might also be required to comply with all applicable privacy laws and regulations to record and maintain certain PII from you by (e.g., recording telephone calls or monitoring email and other network traffic).

Without some of this information we cannot provide you with the services you may request. If you are currently receiving information or marketing communications from us, however, you may opt-out of receiving further communications at any time using one of the contact methods listed below.

Sharing Your PII
Your PII may be combined with information we receive from other sources, or it may be provided to other organizations we work with. This section details that sharing of your PII.

Receiving PII from Third Parties
We may receive information about you from other sources and combine that information with the PII we collect directly from you. Additionally, to promote protection of your identity, we also may collect credit or identity information, which we use to help prevent and detect fraud.

Sharing PII with Third Parties
We may share your PII with our affiliates, service providers, and other third parties. We may do so for the purposes of operating our business, delivering and improving the financial services we provide to you, as well as for other legitimate purposes permitted by applicable law such as sending marketing and other communications related to our business.

We also share personal information for a variety of additional purposes including, but not limited to:
- Within Energy Capital Partners and our affiliates and subsidiaries for data processing or storage purpose
- With business partners and service providers to help facilitate transactions
- In response to a request from law enforcement, government authorities, or other third parties as necessary to comply with legal process or to meet national security requirements

PII From Minors
We do not offer financial services and products to minors and do not intend to collect personal information from children under the age of 18 . We follow all local legal requirements with respect to the collection and processing of a minor’s personal information.

Your PII Rights
The CCPA provides you with certain rights in regard to what we do with your personally identifiable information. This section details those rights, how to exercise them, and what Energy Capital Partners will do in response.

Disclosure
You have the right to request that we disclose to you, free of charge, the categories and specifics of the PII we collect about you. We require a verifiable request from you to ensure that it is, in fact, you who is requesting such a PII disclosure. Once we verify the request, we will provide that information to you.

Your request for disclosure can apply to any such PII mentioned in the previous paragraph for as much as twelve months preceding your request. Be advised that we are not required to disclose such information about the PII we collect about you more than twice in a twelve-month period.

Following our verification of your request, we will disclose to you, unless otherwise restricted by law or regulation, the following PII we collect about you:
1. The categories of personal information we have collected about you
2. The categories of sources from which the personal information is collected
3. The business or commercial purpose for collecting or selling that personal information
4. The categories of third parties with whom we share personal information
5. The specific pieces of personal information we have collected about you

Deletion of PII
Where provided by law, you have the right to request that we delete the PII we have collected from you. Following our verification of your request, we will comply with your request and delete any or all of your PII in our possession that we collected from you and/or any or all such PII in the possession of our service providers, unless ECP is otherwise legally permitted to retain or is otherwise restricted by law or regulation.

Non-Discrimination for Exercising Your PII Rights
We follow the requirements of California Civil Code §1798.125, and will not discriminate against any consumer who exercises the rights set forth in this privacy notice.

Contacting Us to Exercise Your PII Rights
You may contact us in order to exercise any of your rights set forth in this privacy notice by calling this toll-free number 1-866-890-3270 or by contacting the Energy Capital Partner compliance team at compliance@ecpartners.com.