Joule Assets Europe Privacy Information Notice
This document contains the requested information on the collection and processing of data and information (the terms "Data" and "Information" are used interchangeably) performed by Joule Assets Europe Group S.R.L., Largo Augusto 8, 20122 Milano, Italy ("Joule," "Joule Europe" or "Data Controller") .
1. Description of the processing
Joule Europe operates and is the Data Controller of eQuad, a web-based software-as-a-service platform ("eQuad" or the "Platform"), that connects project developers and investors in relation to energy efficiency and renewable energy projects (each, a "Project").
The Platform has two main categories of users - project developers/contractors, who submit a project idea or proposal to the Platform (each, a "Contractor"), and potential investors or financing entities (each, an "Investor"). The Platform works with, and provides data to, third parties such as an energy performance insurance provider (the " Performance Insurance Provider" ) and a provider of quality assurance and due diligence services (the " Quality Assurance Provider"). After Contractor provides Information about its Projects to the Platform, eQuad uses that Information, where appropriate, to (i) evaluate a Project and generate a Project report; (ii) calculate Project metrics; (iii) make introductions to Investors; and (iv) send Project Information to Investor(s), Performance Insurance Provider, Quality Assurance Provider, and to other contractors engaged by the Platform.
1.1 Additional Services offered through the Platform
Two optional services are offered directly through the Platform.
Requesting an insurance quotation from the Insurance Provider
The Platform enables Contractors, at their option, to request an energy efficiency performance insurance quotation directly through the Platform. Upon the Contractor inputting required Information, eQuad generates an spread sheet that contains information required to obtain an insurance quotation, and is emailed as an attachment to the Performance Insurance Provider. Subsequent communications between the Performance Insurance Provider and the Contractor occur outside of the Platform. The Performance Insurance Provider, in its discretion, may issue a quotation for insurance.
Investor Ready Energy Efficiency (IREE) certification process
Contractor may choose to follow the optional IREE certification process developed by the Investor Confidence Project ("ICP") (http://www.eeperformance.org/) (this is apart from the obligatory eQuad preliminary due diligence process performed by eQuad and/or its Quality Assurance Provider). In this process, the Contractor uploads documentation that is accessed and reviewed by the Quality Assurance Provider. Upon successful review, the Quality Assurance Provider will indicate that the Project is ready to submitted to the ICP for the IREE Certification.
The IREE Certificate itself is not awarded by eQuad, but through ICP, in accordance with ICP's procedures. Upon successful review of project documentation on the Platform, the Contractor will be contacted by the Quality Assurance Provider with specific details and instruction on obtaining its IREE Certification.
2. What Data eQuad collects
eQuad collects Information that users provide directly to eQuad or through the Platform. For example, the Platform collects Information about users when users create an online account, fill out a form, subscribe to a newsletter, or otherwise communicate with us.
The types of Information that eQuad collects include:
Personal data, such as user's name, telephone number, and email address.
Information about user's company such as the name, size, personnel, location of the company and the user's role within the company.
Government identification Information such as a company VAT identification number.
Third-party Data, such as Information provided by the user about the user's customer(s).
When user accesses or uses the Platform, the Platform automatically collects device and log Information in order to ensure that every single transaction occurring within eQuad's systems is associated with an authenticated identity. The Platform collects Information about the computer or mobile device user uses to access the Platform, including device identifiers, mobile network Information and the type of browser used. The Platform also logs Information about user's use of the Platform, including access times, IP address or other standard web log Data.
2.1 Information from other sources
eQuad may also obtain Information from other sources and combine that with Information collected directly through the Platform. For example, the Platform may collect non-public personal Information about you from third parties, such as identity verification services. (For example VAT number validation service from VIES - http://ec.europa.eu/taxation_customs/vies/vatResponse.html)
3. Purposes of the processing of the Information
In its capacity as Data Controller, Joule Europe may use your Information for the following purposes:
To present our website and its contents to users.
To provide user with Information, products or services that user requests from Joule.
To notify user about changes to the Platform, or any other products or services that Joule offers or provides through the Platform.
To manage user account(s) and send technical notices, updates, security alerts and support and administrative messages.
To personalize, measure and improve the eQuad services.
To deliver newsletters or any other marketing material.
4. How the Platform shares the Data it collects
The Platform does not share Information with third-parties other than as follows or otherwise described in this document:
Project Information, including company and personal Data concerning the Contractor and its customer(s), are shared with prospective Investors as part of the eQuad basic service - matchmaking Projects to Investors.
Project Information is shared with the Performance Insurance Provider by forwarding Information (typically as part of a spreadsheet) to a dedicated email address of the Performance Insurance Provicer. This permits issuance of an insurance premium quotation to the Contractor based on the Project Data submitted on the Platform. Obtaining an insurance quotation is an optional service.
Project Information and Project documentation can be accessed by the Quality Assurance Provider directly though the Platform. Additionally, the Quality Assurance provider can view all the Information provided through the ICP Ready service and the IREE Certification process
Information collected on the Platform may be shared internally within and among Joule Europe and its parents, subsidiaries and affilates, including Joule Assets Inc. (USA), Joule Assets Europe Ab Oy (Finalnd), and Joule Capital, LLC (USA).
We may share personal Data with a limited number of third-party service providers, in order for us to provide or improve our services to users. These service providers may include payment processors, customer support, analytics providers, and other similar services.
Other third parties who Joule works with in support of its business.
Joule is not responsible for how investors, Performance Insurance Provider, Quality Assurance Providers, and other third parties who receive Information from Joule use, secure or care for Information that is provided to them by Joule.
5. How long the Platform stores user Information
The Information collected by the Platform is stored for the period of time necessary to perform the services provided to you by the Platform, to perform services that you request –both of which periods depend on the status of user's application and on the services in question. The Platform also maintains Information as archival business records after services are performed.
6. Our legitimate interest to process the Data
The processing of the Data is performed to take the steps we deem appropriate to supply you with the services described herein in connection with your agreement or intention to use the Platform. Hence, no consent is necessary since we are pursuing a legitimate business interest to perform pre-contractual or contractual activity at your request.
7. Nature of the provision of personal Data and related consequences
As discussed in point 6, above, user's provision of Data is on a voluntary basis, nevertheless necessary to enter into a contract; if you do not supply the required Data to the Platform, the Platform may not process the application and user may not have access to the services.
8. User's rights
It is important that the user is aware of user's rights related to the Data provided to the Platform, so please read this document carefully.
In summary, according to the law, the user's rights include the right to require access to user Data and to request their correction or erasure; user may also require the restriction of processing or to object to the Platform's processing of them; user also has the right to Data portability. Finally, you may lodge a complaint with the Italian Data protection Authority (Garante per la protezione dei dati).
More information about user right is described in sections 16 through 20 of the General Data Protection Regulation (Regulation (EU) 2016/679 of April 27, 2016).
9. Automated processing
Some of the operations related to Project evaluation are automated. However, no automatic decision is taken in the context of the processing of your personal Data.
10. How Data is stored and processed
Joule takes all measures reasonably necessary to protect user Data from unauthorized access, alteration, or destruction; maintain Data accuracy; and help ensure the appropriate use of user Information.
This includes protect user Information using reasonable physical, electronic and administrative security measures to prevent loss or theft, and unauthorized access, disclosure, copying, use or modification. Access to the Platform requires authentication, and conveyed information is encrypted using industry-standard transport layer security technology (TLS). In addition, users' connection to the Platform requires a valid, trusted server certificate. Physical access to the servers is restricted only to authorized personnel of our information processing contractors.
11. Transfer of personal data to a third country
As mentioned above (sec. 4.4), we may share Information within our parents, subsidiaries and affiliates, including our US-based companies. These transfers shall take place on the basis of the Standard Contractual Clauses (Decision 2010/87 of the EU Commission of February 5, 2010).
12. Links to other websites
The eQuad Platform and related websites may contain links to enable user to visit other websites easily. However, once user has used these links and left the eQuad site, the Platform does not have any control over that other website. Therefore, the Platform shall not be responsible for the protection and privacy of any Information user provides while visiting such sites and such sites are not governed by this privacy statement. User should exercise caution and review the privacy statement applicable to the website in question.
13. Joule's contact information
Any and all requests for information on the processing of personal Data and any request to exercise user rights must be sent to the following address: email@example.com.