Privacy Policy

CPRA External Privacy Policy

Policy Last Updated: 6.30.23

Policy Number: CEI.POL.0520.01

Introduction

Cupertino Electric, Inc. (CEI) developed this Privacy Policy to explain how our company collects, retains, uses, processes, and discloses your personal data when you visit our websites, use our services, or visit us in person. This Privacy Statement is designed to help you obtain information about our privacy practices and to help you understand your privacy choices when you use our websites, and services. 

CEI’s Commitment to Privacy

CEI’s privacy commitments are fundamental to the way we run our business. These commitments apply to everyone who has a relationship with CEI - including customers, vendors, partners, contractors, subcontractors, and website visitors. Cupertino Electric is committed to providing you with the best overall experience in our services. We strive to strike the right balance between using your personal data to ensure the quality of those experiences and protecting your privacy.

Scope

This policy applies to all personal data CEI collects about you, personal information we collect directly from you, information we automatically collect,  and personal information we collect from third parties.

Personal, Deidentified, and Aggregate Information

Personal data, also referred to as personal information (PI) or personally identifiable information (PII) is information that identifies, or reasonably could be used to identify you. Deidentified information (i.e., information that can't be used to infer information about, or otherwise be linked to you specifically) and aggregate information (i.e., information  that relates to a group or category of consumers, from which individual consumer identities have been removed) are not considered personal data.  We maintain deidentified information in a deidentified form and do not attempt to reidentify it, except that we may attempt to reidentify the information just to determine whether our deidentification processes function correctly.

Examples of personal data include your: (i) Name, (ii) Mailing address, (iii) Email address, (iv) Phone number, (v) Date of birth or age, (vi) Credit/debit card number, (vii) Agreement information, (viii) Mobile device information, (ix) How you use our websites, (x) Geo-location related information, (xi).

Personal Data We Collect

CEI may collect and use the following information. (a) Identifiers, (b) Personal Information Described in Cal. Civ. Code §1798.80, (c) Commercial Information, (d) Internet or Other Electronic Network Activity (e.g., Website Traffic, Search Engine Optimization, and Cookies), (e) Audio, Electronic, Visual, or Similar Information (e.g., voicemail and surveillance camera recordings), (f) Professional or Employment-Related Information (e.g., Identifiers, including name, phone number and email address), and (g) Inferences (drawn from any of the information above).

How CEI Uses Personal Data

CEI may use your information, including personal data, to provide you with the best services, and overall experience that we can. We may use your personal data to support our business functions, such as fraud prevention, marketing, and legal functions. 

Providing Products and Services, including:

• To deliver our products and administer our services.
• To communicate with you.
• To improve our products and services, develop new products and services, and conduct research on further improvements.
• To enhance your experience using our products and services and to personalize your online experience.

Support and Marketing, including:

• For customer support.
• To respond to any requests, queries, suggestions, feedback, or comments you may have.
• To send you marketing information about our products and services, including notifying you of marketing events, membership and rewards programs, promotions, and sweepstakes, with your consent in accordance with applicable law.
• To inform you of any changes to the services, your account (if applicable), this Privacy Policy, or any other policies or terms in relation thereto.
• To perform operations to maintain services, including to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends.

Monitoring, Security, and Compliance, including:

• To administer and protect our business and our Website (including troubleshooting, analysis, testing, system maintenance, support, reporting and hosting of data, and preventing fraud and abuse).
• To store, host, or backup (whether for disaster recovery or otherwise) our services or any data contained therein.
• To protect the rights, property, or safety of CEI, you, or others.
• In connection with a corporate transaction, sale, or assignment of assets, merger, divestiture, or other changes of control or financial status of CEI or any of its subsidiaries or affiliates.
• To report suspected criminal conduct to law enforcement and cooperate in investigations.
• To exercise CEI’s rights under applicable law and to support any claim, defense, or declaration in a case or before a jurisdictional and/or administrative authority, arbitration, or mediation panel.
• To ensure compliance with applicable laws and regulatory obligations.

Incidental Purposes: Any incidental purposes related to, or in connection with, the above.

Sources of Your Personal Data

CEI collects your personal information from the following categories of sources.

• Software Applications
• Electronic Files 
• Storage Servers
• Hardcopies
• Websites
• Electronic Devices
• SaaS Applications
• Contact Lists
• Contracts/Subcontracts
• DOT Applications
• Employee Applications (Digital or Hardcopy)
• Workplace Investigations
• Risk/DMV Records
• Vendor Agreements

Retention of Personal Data

CEI follows all applicable laws governing the retention of your personal data. The factors that influence how long we retain your data include: 

• Personal information is needed to provide services, and experiences to you.
• Personal information is needed to obtain payment and contact you.
• Personal information is needed to comply with legal obligations and to pursue or defend against legal claims.
• CEI retains the data collected from you for different periods of time depending on your relationship to CEI and the purposes for which we collected your personal information. The data CEI retains falls into the following categories:
• Information retained until you remove it – we keep this data until you ask us to delete it or until retention obligations expire. Types of information included in this category is  contact information provided in a Contact Form.
• Information that CEI deletes after a specific period of time or in response to an event – we store this data for a predetermined period of time. We set retention timeframes based on the reason for its collection and compliance with applicable law. For example, information provided that is provided to CEI in the Supplier Registration Form (Name, Email, and Supplier Tax information etc.) is kept as long as required by law.
• Information retained for specific business or legal purposes – Sometimes business and legal requirements oblige us to retain certain information, for specific purposes, for an extended period of time. For example, when we process a payment for you or when you make a payment to us, we will retain this data for longer periods of time as required for tax or accounting purposes. 

Disclosures of Personal Data

CEI discloses personal information to third-party service providers; in corporate transactions to avoid disputes in the case of a merger or bankruptcy reorganization; and to government agencies as required by law to do so, to unaffiliated third parties in litigation (e.g., in response to a subpoenas), and to law enforcement. 

We do not sell or share your personal information for advertising purposes, where "sell" or “share” means disclosing personal information to third parties for cross-context behavioral advertising. Without limiting the foregoing, we have not, and have no actual knowledge that we have, sold or “shared” the personal information of individuals of any age, including the personal information of children under 16, in the last 12 months.

Security for Personal Data

CEI cannot guarantee that any information submitted through the Website will remain confidential and secure. Therefore, CEI advises against sending any information that you consider “confidential, sensitive or proprietary.” If you wish to send information that you deem “confidential, sensitive or proprietary” you are recommended to reach out to the CEI Information Technology team to leverage a secure transmission platform.

Personal Information collected on the Website may be retained indefinitely.

Rights of California Residents

Notice at Collection for California Residents:

CEI collects the categories of personal information identified in Section 4.0, Personal, Deidentified, and Aggregate Information, above, for the purposes identified in Section 5.0, How CEI Uses Personal Data and retains that personal information for the period described in Section 7.0, Retention of Personal Data above. We do not sell your personal information or disclose it for cross-context behavioral advertising (“sharing”). We also do not collect or process sensitive personal information for the purpose of inferring characteristics about you. To the extent you provide CEI with personal information about other California residents, you are responsible for providing this notice to them.

Subject to applicable law, California residents have the following rights:

• Right to Know: You have the right to submit a verifiable request for specific pieces of your personal information obtained from or about you and for information about CEI’s collection, use, and disclosure of your personal information. Please note that the CPRA’s right to obtain “specific pieces” does not grant a right to the whole of any document that contains personal information, but only to copies of items of personal information. Moreover, California residents generally just have a right to know categories, for example, categories of third parties to which personal information is disclosed, but not the individual third parties. 
• Right to Correct: You have the right to submit a verifiable request for the correction of inaccurate personal information maintained by CEI, taking into account the nature of the personal information and the purposes of processing the personal information.
• Right to delete the personal data we have collected from you.
• Right not to be the subject of unlawfully discriminatory treatment for the exercise of privacy rights described above. 
• Right to limit use and disclosure of sensitive personal information, if applicable. 

Note on Sensitive Personal Information: CEI does not infer characteristics from sensitive personal information. CEI uses sensitive personal information only as necessary to perform the services that the average person would reasonably expect when requesting those services, to ensure security and integrity, short term transient use, to maintain the quality of our services, or for other purposes permitted by the California Privacy Rights Act (CPRA) and implementing regulations  without the right to opt out.

Exercising Your Rights

You may exercise any applicable rights described in this policy using this Privacy Rights Request Form or by calling the CEI Privacy Tollfree Number, 1-833-299-6662.

We match personal information that you provide us against personal information we maintain in our files. The more risk entailed by the request (e.g., a request for specific pieces of personal information), the more items of personal information we may request to verify your identity. If we cannot verify your identity to a sufficient level of certainty to respond securely to your request, we will let you know promptly and explain why we cannot verify your identity.

California residents may designate an authorized agent to make a CPRA request on their behalf by completing and signing the form available here CPRA Designated Authorized Agent Form. If an authorized agent submits a request on your behalf, the authorized agent must submit with the request the Designate Authorized Agent Form signed by you that authorizes the authorized agent to submit the request on your behalf. In addition, we may ask you or your authorized agent to follow the applicable process described above for verifying your identity. 

Conflicts between Law and this Policy

If there is a conflict between this policy and an applicable law, the applicable law applies.

Cookies

Cookies keep track of your visits to websites and activity online. CEI uses Google Analytics G4, at the time of this publication, and GA4 uses first-party cookies to separate unique users and unique sessions from a single user. GA4 does not require you to set cookies on your website to receive data and transmit it to Google Analytics.

A cookie is a small piece of data that is stored on your computer, tablet, or phone. CEI uses cookies and similar technologies to improve our services. Cookies are not required for certain parts of our services. You can choose not to allow some type of cookies. If applicable, please change your cookie preferences in your browser.

Pixels

Pixels, like cookies, allow CEI to provide you with a superior website experience. Google has built Google Analytics 4 so that it doesn't rely on cookies (tracking pixels). GA4 leverages Google Signals and machine learning to help generate a more complete view of user behavior on a website.

Automatic Collection During Website Session

We use the data we collect during your time on our websites to improve your future experience. The data collected during the course of browsing our websites will be analyzed and used to generate statistics that help us improve our website, products, and services to you.

Restriction on Children's Information

Our communications, business process, and services are not directed to, and we do not, specifically market to individuals under the age of eighteen (18). We do not collect information from anyone under 13 years of age. The services we provide, together with our Website, are all directed to individuals who are at least 18 years old. If you are under the age of 13, you are not authorized to use our services or the Website. 

Contact Us / Request Forms

If you have any questions or concerns, please contact the Information Management Systems Team.

Contact

CEI Information Management Systems

CEIPrivacy@cei.com or 1-833-299-6662.

Request Forms

Privacy Rights Request Form

CPRA Designated Authorized Agent Form