Privacy Policy

Last updated April 15, 2020

ESAI Energy LLC (“ESAI”, “we”, “us”, “our”, the “Company”) is an energy research and forecasting firm. Our clients include key players in the liquid energy markets as well as energy consumers and national governments. We collect information for many reasons. For example, the information that you provide to us enables us to, among other things: provide consulting services to you, give you access to our research and analysis, provide you with information you’ve requested, and provide you with the best possible client service.

This Privacy Policy describes our policies and procedures on the collection, use, and disclosure of your information when you use our website and services and tells you about your privacy rights and how the law protects you.  By using our website and services, you agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Definitions

The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

For the purposes of this Privacy Policy:

  • Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
  • Account means a unique account created for you to access certain parts of our Website and services.
  • Business, for the purpose of the CCPA, refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.
  • CCPA means the California Consumer Privacy Act.
  • Company refers to ESAI Energy LLC, a Massachusetts limited liability company with a principal place of business at 401 Edgewater Pl, Wakefield, MA 01880. For the purpose of the GDPR, the Company is the Data Controller.
  • Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
  • Cookies are small files that are placed on your computer, mobile device or any other device by a website, containing the details of your browsing history on that website among its many uses.
  • Country refers to: Massachusetts, United States
  • Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
  • Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
  • GDPR means the General Data Protection Regulation.
  • Personal Data is any information that relates to an identified or identifiable individual. For the purposes for GDPR, Personal Data means any information relating to you such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity. For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.
  • Sale, for the purpose of the CCPA, means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s Personal information to another business or a third party for monetary or other valuable consideration.
  • Website Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the services we provide, to provide services on our behalf, to perform services related to the service we provide, or to assist the Company in analyzing how our Website and services used. For the purpose of the GDPR, Website Providers are considered Data Processors.
  • Usage Data refers to data collected automatically, either generated by the use of the Website or from the Website infrastructure itself (for example, the duration of a page visit).
  • Website refers to ESAI Energy’s website, accessible from https://www.esaienergy.com, and landing pages or blog posts accessible via the domain https://info.esaienergy.com.
  • You means the individual accessing or using our Website and services, or the company or other legal entity on behalf of which such individual is accessing or using our Website and services, as applicable. Under GDPR, you can be referred to as the Data Subject or as the User.

Collecting and Using your Personal Data

Types of Data Collected

Information You Provide to Us

While using our Website and services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you, respond to your inquiries and requests, and provide services to you. Examples of personally identifiable information we may collect, depending on the transaction and/or communication, include:

  • Email address
  • First name and last name
  • Phone number
  • Address, city, state, province,zip/postal code
  • Company name and job title
  • Usage Data
Usage Data

Usage Data is collected automatically when using the Website.

Usage Data may include information such as your device's Internet Protocol (IP) address, browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

When you access the Website by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

We may also collect information that your browser sends whenever you visit our Website or when you access the Website by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on our Website and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze our Website.

You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our Website.

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on your personal computer or mobile device when you go offline, while Session Cookies are deleted as soon as you close your web browser.

We use both session and persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide you with services available through the Website and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that you have asked for cannot be provided, and we only use these Cookies to provide you with those services.

Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies
Administered by
: Us
Purpose
: These Cookies identify if users have accepted the use of cookies on the Website.

Functionality Cookies

Type: Persistent Cookies
Administered by
: Us
Purpose
: These Cookies allow us to remember choices you make when you use the Website, such as remembering your login details and your user settings. The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use the Website.

Tracking and Performance Cookies

Type: Persistent Cookies
Administered by
: Third-Parties
Purpose
: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new advertisements, pages, features or new functionality of the Website to see how our users react to them.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy.

Email and Other Communications

We may contact you, by email or other means; for example, we may communicate with you about services you are receiving from us or about information you have requested. When we do this, we may receive a confirmation when you open an email from us. This confirmation helps to improve our service. If you do not want to receive email from us, please indicate your preference by clicking on the unsubscribe link in any of our emails.

Please note that if you do not want to receive legal notices from us, those legal notices will still govern your use of our Website and services, and you are responsible for reviewing such legal notices for changes.

Information Received from Third Parties

We subscribe to and receive Personal Data from ZoomInfo, a third-party business directory. We have no control over ZoomInfo’s privacy policy and practices, although ZoomInfo has represented to us that it aggregates data from public sources, omits non-business contact information from its database, and is generally compliant with applicable privacy laws.

We may also use additional business directories as the need for such services arise. We have no control over these companies’ privacy policies and practices but will insist on said companies’ assurance to adhere to all applicable privacy laws.

Personal Data We Have Collected in the Last 12 Months

We have collected the following categories of Personal Data in the 12 months immediately preceding the effective date of this Privacy Policy: names; contact information; company, job, and professional information; user locations; Website preferences; user names and e-mail addresses in combination with user-selected passwords and security questions needed to access Accounts; IP addresses; information related to the use of the Website; users’ browser types; confirmation when users have read or opened our emails; self-identifying information provided by the user regarding their topic(s) of interest.

Use of your Personal Data

We may use Personal Data for the following purposes:

  • To provide and maintain our Website, including to monitor the usage of our Website.
  • To manage your Account: to manage your registration as a user of the Website. The Personal Data you provide can give you access to different functionalities of the Website that are available to you as a registered user.
  • For the performance of a contract and other services: to perform contracts and other services you have engaged us to perform.
  • To contact you: To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication regarding updates or informative communications related to our services, services you have engaged us to perform, products you have purchased from us, security notices, and legally-required notices.
  • To provide you with news, offers and general information about our services and activities that may be relevant to you unless you have opted not to receive such information.
  • To manage your requests: To attend and manage your requests to us.

We may share your personal information in the following situations:

  • With website providers: we may share your personal information with website providers to monitor and analyze the use of our Website, to contact you, or for payment processing.
  • Per legal requirements: under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). We may also disclose your Personal Data in the good faith belief that such action is necessary to comply with a legal obligation, protect and defend the rights or property of the Company, prevent or investigate possible wrongdoing in connection with the Website or our services, protect the personal safety of Users of the Website or the public, and to protect or defend ourselves against legal liability.

Retention of your Personal Data

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when longer-term analysis is necessary, or when this data is used to strengthen the security or to improve the functionality of our Website, or we are legally obligated to retain this data for longer time periods.

Transfer of your Personal Data

Your information, including Personal Data, is processed on our servers, at our office, and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Unless noted otherwise in this Privacy Policy, we store and process all Personal Data that we collect from you on information systems in the United States.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your Personal Data and other personal information.

Detailed Information on the Processing of your Personal Data

Certain third parties have access to your Personal Data only to perform tasks on our behalf and are obligated not to disclose or use your Personal Data for any other purpose.

Analytics

We may use third-party services to monitor and analyze the use of our Website.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Website. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having your activity on the Website made available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

Email Marketing

We may use your Personal Data to contact you with newsletters, alerts, promotional materials, and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

We may use third-party email marketing service providers to manage and transmit the emails we send to you.

Behavioral Remarketing

The Company uses remarketing services to advertise on third-party websites to you after you have visited our Website. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Website.

Twitter

Twitter remarketing service is provided by Twitter Inc.

You can opt-out from Twitter's interest-based ads by following their instructions: https://support.twitter.com/articles/20170405

You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy

LinkedIn

LinkedIn remarketing service is provided by LinkedIn Inc.

You can opt-out from LinkedIn’s interest-based ads by following their instructions: https://www.linkedin.com/help/linkedin/answer/90274/manage-your-linkedin-ads-settings?lang=en

You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://www.linkedin.com/legal/privacy-policy

Usage, Performance and Miscellaneous

We may use other third-party services, apps, plugins, and products to improve the performance and security of our Website.

Invisible reCAPTCHA

We use an invisible captcha service named reCAPTCHA. reCAPTCHA is operated by Google.

The reCAPTCHA service may collect information from you and from your device for security purposes.

The information gathered by reCAPTCHA is held in accordance with the Privacy Policy of Google: https://www.google.com/intl/en/policies/privacy/

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

  • Consent: you have given your informed consent, for processing Personal Data for one or more specific purposes, by confirming the prompts produced by this Website and continuing to use the Website, consistent with this Privacy Policy and any other documentation we may provide.
  • Performance of a contract: it is necessary to collect and process certain Personal Data for the performance of an agreement with you and/or for any pre-contractual communications, preparations, and obligations.
  • Legal obligations: it may be necessary to process Personal Data for compliance with a legal obligation to which we are subject.
  • Vital interests: it may be necessary to process Personal Data to protect your vital interests or of those of another natural person.
  • Public interests: it may be necessary to process Personal Data to carry out a task that is in the public interest.
  • Legitimate interests: it may be necessary to process Personal Data for the purposes of pursuing the Company’s legitimate interests.

At your request, we can provide additional information about the specific legal basis that applies to particular transactions and particular processing of Personal Data, including whether the provision of Personal Data is a statutory or contractual requirement or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of your Personal Data and to guarantee you can exercise your rights.

You have the right under this Privacy Policy, and by law if you are within the EU, to:

  • Request access to your Personal Data. The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you. This also enables you to receive a copy of the Personal Data we hold about you.
  • Request correction of the Personal Data that we hold about you. You have the right to have any incomplete or inaccurate information we hold about you corrected.
  • Object to processing of your Personal Data. This right exists where we are relying on a legitimate interest as the legal basis for our processing and you want to object to our processing of your Personal Data. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
  • Request erasure of your Personal Data. You have the right to ask us to delete or remove Personal Data when there is no good reason for us to continue processing or retaining it.
  • Request the transfer of your Personal Data. We will provide to you, or to a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to Personal Data that we process through automated means and where our legal basis for processing the Personal Data is your consent or for the performance of a contract with you.
  • Withdraw your consent. You have the right to withdraw your consent on using your Personal Data. If you withdraw your consent, we may not be able to provide you with access to certain functionalities of the Website or certain services you may request.

Exercising of your GDPR Data Protection Rights

You may exercise your rights of access, rectification, cancellation and opposition by contacting us by using one of the contact methods provided at the end of this Privacy Policy. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.

CCPA Privacy

Your Rights under the CCPA

Under this Privacy Policy, and by law if you are a resident of California, you have the following rights:

  • The right to notice. You must be properly notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
  • The right to access / the right to request. The CCPA permits you to request and obtain from the Company information regarding the disclosure of your Personal Data that has been collected in the past 12 months by the Company or its subsidiaries to a third party for the third party’s direct marketing purposes.
  • The right to say no to the sale of Personal Data. You have the right to ask the Company not to sell your Personal Data to third parties. You can submit such a request by visiting our Privacy Settings  web page.
  • The right to know about your Personal Data. You have the right to request and obtain from the Company information regarding the disclosure of the following:
  1. The categories of Personal Data collected
  2. The sources from which the Personal Data was collected
  3. The business or commercial purpose for collecting or selling the Personal Data
  4. Categories of third parties with whom we share Personal Data
  5. The specific pieces of Personal Data we collected about you
  • The right to delete Personal Data. You have the right to request the deletion of your Personal Data that have been collected in the past 12 months.
  • The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your Consumer’s rights, including by:
  1. Denying goods or services to you
  2. Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
  3. Providing a different level or quality of goods or services to you
  4. Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising your CCPA Data Protection Rights

In order to exercise any of your rights under the CCPA, and if you are a California resident, you can contact us by using one of the contact methods provided at the end of this Privacy Policy or visit our "Do Not Sell My Personal Information" section or web page.

The Company will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Do Not Sell My Personal Information

We do not sell personal information. However, the third-party service providers we partner with (for example, our advertising partners) may use technology on the Website that "sells" personal information as defined by the CCPA law.

If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser you use. You may need to opt out on every browser that you use.

Website

You can opt out of receiving personalized ads served by third-party service providers by following our instructions presented on the Website:

  • From Our "Cookie Consent" notice banner
  • Or from the "CCPA Opt-out" section on our webpage
  • Or from the "Do Not Sell My Personal Information" section on our webpage

The opt-out will place a cookie on your computer that is unique to the browser you use to opt out. If you change browsers or delete the cookies saved by your browser, you will need to opt out again.

Mobile Devices

Your mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:

  • "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices
  • "Limit Ad Tracking" on iOS devices

You can also stop the collection of location information from your mobile device by changing the preferences on your mobile device.

"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Website does not respond to Do Not Track signals.

However, some third-party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.

Children’s Privacy

Our Website is not intended for and does not address anyone under the age of 16. If you are under the age of 16, you must leave this Website immediately. We do not knowingly collect personally identifiable information from anyone under the age of 16. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from anyone under the age of 16 without verification of parental consent, we take steps to remove that information from our servers.

We also may limit how we collect, use, and store some of the information of users between 16 and 18 years old. In some cases, this means we will be unable to provide certain functionality of the Website or certain services to these users.

If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent's consent before we collect and use that information.

Links to Other Websites

Our Website may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via a prominent notice on our Website, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, or if you would like to make requests with respect to your Personal Data, you can contact us: