Privacy Policy

We understand that you are aware of and care about your own personal privacy interests, and we take that seriously. DV Analytics, LLC and its subsidiary, Energia Analytics, LLC, are committed to maintaining your privacy. This Privacy Notice describes Energia’s policies and practices regarding its collection and use of your personal data, and sets forth your privacy rights. We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Notice as we undertake new personal data practices or adopt new privacy policies.

How we collect and use your personal information

As visitors of our website and users of our platform, Energia may collect personal information directly from you via questionnaires, surveys, and the registration process and may collect personal information indirectly from you. We use this information to provide prospective customers with services. This information may include, but is not limited to:

‍

• Name
• Email
• Phone Number
• Address
• Date of Birth
• Social Security Number
• Employer Name
• Job Title
• Citizenship
• Investment Suitability Information
• Investment Experience
• Custodial Account Information
• Bank Account Information
• Accredited Investor Information
• Entity Information

‍

Indirect information is collected when you access our website and includes, but is not limited to, IP addresses, click paths, page views, operating system, and browser information. This data may be used to further improve our website and understand how the website is being used. We may also use your IP address to help diagnose problems with our server and to administer our website, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences.

How we share information with third parties

We do not sell personal information to anyone and only share it with third parties who are facilitating the delivery of our services. Energia may share your information (i) to satisfy any applicable law or regulation, (ii) to comply with judicial proceedings, court orders, or legal processes served to us, (iii) to detect and prevent fraud, (iv) to detect and prevent any technical issues, (v) to enforce our terms and conditions, and (vi) to streamline subscription document processing and transfer of assets at your request. Third party companies may send information to you, including information about our products, services, and events. We may also gather aggregated data about our services and website visitors and disclose the results of such aggregated (but not personally identifiable) information to our partners, service providers, advertisers, and/or other third parties for marketing or promotional purposes.

Data storage and retention

Your personal data is stored by Energia on its servers, and on the servers of the cloud-based database management services Energia engages, located in the United States. Energia retains service data for the duration of the customer’s business relationship with Energia and for a period of time thereafter, to analyze the data for Energia’s own operations, and for historical and archiving purposes associated with Energia’s services. Energia retains prospect data until such time as it no longer has business value and is purged from Energia systems. All personal data that Energia controls may be deleted upon verified request from Data Subjects or their authorized agents. For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact us at: privacy@dv-analytics.io

California Residents’ Privacy Rights

The California Consumer Privacy Act, CCPA, requires us to provide a summary of privacy rights for California residents including how we collect, use, and disclose personal information. California residents can request a report of their personal information at privacy@dv-analytics.io. Pursuant to the CCPA, California residents may opt out of sharing their personal information to such third parties.

Children’s data

WE DO NOT ALLOW INDIVIDUALS WHO WE KNOW ARE UNDER 18 YEARS OLD TO PARTICIPATE IN OUR PLATFORM OR SERVICES. YOU MUST BE AT LEAST 18 YEARS OLD TO USE OUR PLATFORM AND SERVICES. We do not knowingly attempt to solicit or receive information from children.

Transferring personal data to the U.S.

18pxEnergia has its headquarters in the United States. Information we collect about you will be processed in the United States. By using Energia’s services, you acknowledge that your personal information will be processed in the United States. The United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the General Data Protection Regulation, GDPR. Pursuant to Article 46 of the GDPR, Energia is providing for appropriate safeguards by entering binding, standard data protection clauses, enforceable by data subjects in the EEA and the UK. These clauses have been enhanced based on the guidance of the European Data Protection Board and will be updated when the new draft model clauses are approved. Depending on the circumstance, Energia collects and transfers to the U.S. personal data with consent; to perform a contract with you; or to fulfill a compelling legitimate interest of Energia in a manner that does not outweigh your rights and freedoms. Energia endeavors to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with Energia and the practices described in this Privacy Policy. Energia also enters into data processing agreements and model clauses with its vendors whenever feasible and appropriate.

‍

For more information or if you have any questions, please contact us at privacy@dv- analytics.io.

European General Data Protection Regulation

The European Union’s General Data Protection Regulation (GDPR) and other countries’ privacy laws provide certain rights for data subjects. Data Subject rights under GDPR include the following:

‍

• Right to be informed
• Right of access
• Right to rectification
• Right to erasure
• Right to restrict processing
• Right of data portability
• Right to object
• Rights related to automated decision-making including profiling

‍

This Privacy Notice is intended to provide you with information about what personal data Energia collects about you and how it is used.

‍

If you wish to confirm that Energia is processing your personal data, or to have access to the personal data Energia may have about you, please contact us.

‍

You may also request information about: the purpose of the processing; the categories of personal data concerned; who else outside Energia might have received the data from Energia; what the source of the information was (if you didn’t provide it directly to Energia and how long it will be stored. You have a right to correct (rectify) the record of your personal data maintained by Energia if it is inaccurate. You may request that Energia erase that data or cease processing it, subject to certain exceptions. You may also request that Energia cease using your data for direct marketing purposes. In many countries, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how Energia processes your personal data. When technically feasible, Energia will—at your request—provide your personal data to you.

‍

Reasonable access to your personal data will be provided at no cost. If access cannot be provided within a reasonable time frame, Energia will provide you with a date when the information will be provided. If for some reason access is denied, Energia will provide an explanation as to why access has been denied.

‍

For questions or complaints concerning the processing of your personal data, you can email us at privacy@dv-analytics.io. Alternatively, if you are located in the European Union, you can also have recourse to the European Data Protection Supervisor or with your nation’s data protection authority.

Cookies at Energia

Energia uses cookies to improve your website experience. Cookies are a tracking technology in the form of small text files that may be stored locally on your computer that help store specific information such as user preferences, authentication information, and statistical information. Energia may use information from cookies to tailor advertisements and conduct research. You can find more information about how to prevent your website browser from accepting new cookies by accessing the help menu on most website browsers. The Energia Privacy Policy covers our use of cookies but does not cover any third party’s use of cookies on our website. Energia does not have access or control over third party’s use of cookies. BY ACCESSING AND USING THE ENERGIA.COM WEBSITE, YOU ARE CONSENTING TO THE USE OF TRACKING TECHNOLOGIES SET FORTH IN THIS PRIVACY POLICY.

Questions, concerns, or complaints

If you have questions, concerns, complaints, or would like to exercise your rights, please email us at privacy@dv-analytics.io.

‍

You may also contact us by mail at:

‍

Energia

1700 West Loop South

Suite 450

Houston, TX 77027