Last Revised: March 7, 2023  

Inclusive Prosperity Capital, Inc. (“Company” or “We“) respect your privacy and are committed to protecting it through our compliance with this policy. 

This Privacy Notice Describes: 

• The types of information we may collect from you or that you may provide when you visit our websites at www.inclusiveteam.org (our or the “Website“); 
• Our practices for collecting, using, maintaining, protecting, and disclosing that information, including sharing that information with third parties; and 
• How we store and secure information. 

This Privacy Notice Applies to Information We Collect: 

• On this Website. 
• In email, text, and other electronic messages between you and this Website. 
• Through mobile and desktop applications you access or download from this Website, which provide dedicated non-browser-based interaction between you and this Website. 
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy. 
• Information collected on portals accessed through our Website or from links provided by us or our subsidiaries, if those portals include links to this policy. 

It does not apply to information collected by: 

• Us offline or through any other means, including on any other website operated by any third party; or 
• Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website. 

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Privacy Notice. This policy may change from time to time (see Changes to Our Privacy Notice). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. 

How to Contact Us  

If you have any questions, concerns or complaints about our Privacy Notice or our data collection or processing practices, or if you want to report any suspected security violations to us, please contact us at the following address or email address: 

Inclusive Prosperity Capital, Inc.
ATTN: Legal
75 Charter Oak Avenue, Suite 1-103
Hartford, CT 06106

legal@inclusiveteam.org
(203) 433-5060 

Information We Collect  

We collect several types of information from and about users of our Website, including information: 

• By which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline (“personal information“); 
• That is about you but individually does not identify you; and/or 
• About your internet connection, the equipment you use to access our Website, and usage details. 

We collect this information: 

• Directly from you when you provide it to us. 
• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies. 

Information Users Provide to Us.  We will collect data that users voluntarily provide to us.  

1. Onboarding Information.  We collect information users provide to us on the Website.  We will collect a user’s name, email address, company name, business telephone number, user name, and user password.     
2. Contact Us/Support.  If a user provides us with feedback, contacts us via e-mail, or contacts us for support services, we will collect the user’s name and e-mail address, as well as any other content included in the e-mail, in order to send the user a reply. 

Information Collected From Users.  Some users that access special portals through the Website will input information into the Website portal about the project or customer they are referring, applying for or monitoring, relevant information, and project contractors.   

1. Project Information. Users using a portal will input information into the Platform regarding project types, the scope of work, energy savings information, cost information and other information relevant to the particular project, including related project documentation and forms.  
2. Owner Information.  We collect owner name, address, email, phone number, and secondary addresses.  
3. Loan Information.  Intermediaries or lenders may provide us with information including approval status, loan amount, payment amount, application number, loan number, term, closing data, and related information. 
4. Borrower Financial and Corporate Information.  Users provide us with financial and corporate information such as financial statements, tax returns, governing documents, corporate resolutions, and supporting information.
5. Contractor Information.  We may collect information related to relevant contractors, such as license number, insurance information, professional data, name, and address.  
6. Project-related Information.  Users may provide information on projects including permits, quotes, inspection reports, plans, equipment information, information on other loans related to the project, and energy audits.  
7. Developer Information.  We may collect information related to relevant developers, insurance information, professional data, name, and address.  

Information Collected via Technology.   

1. Automatically Collected. When a user interacts with the Website, we may automatically collect certain technical information about the user’s equipment, browsing actions and patterns. That information may include Internet Protocol (“IP”) address (a number that is automatically assigned to a user’s computer when using the Internet, which may vary from session to session), domain name, browser type, Internet service provider (“ISP”), mobile device information, referring/exit pages, operating system, date/time stamp, and clickstream data.  We use this information to analyze trends, administer the Website, track users’ movements around the Website, gather demographic information about our user base as a whole, and better tailor our products and services to our users’ needs.  For example, some of the information may be collected so that when a user visits the Website again, it will recognize the user. 
2. Cookies.  Like many online services, we use cookies and similar technologies to collect information about a user’s visit to the Website.  “Cookies” are small pieces of information that a website sends to a user’s computer’s hard drive while a user is viewing the Website.  We use Cookies and similar technologies to make the Website more useful to our users and to tailor the experience with us to meet each user’s needs.  We do not use cookies for advertising, remarketing or sharing data with any third party. 
3. Server Logs.  Our server logs store the access date and pages a user views, but we do not store a user’s IP address. 
4. Error Monitoring.  Our error monitoring service tracks our application’s errors/crashes automatically.  This service will record the user’s e-mail address, the page viewed when the error occurred, and the date/time the error occurred.  This way we can work to fix the errors on a going forward basis. 

Links to Third Party Websites 

The Website may contain links to third-party websites and services (e.g. a website for payment, construction management, or lead management purposes, servers and application providers) and some of those third-party websites may be co-branded with the IPC logo (the “Third Party Services”).  We do not control (and are not responsible for) third party content or privacy practices. Any personal data a user provides to such Third Party Services is not covered by this Privacy Notice.  Third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use the Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with other targeted content. We encourage users to review carefully the legal and privacy notices of all other digital services that users visit. 

How We Use and Share Users’ Information 

We use users’ information only for purposes of providing content and services to you.  We do not sell users’ information to anyone without a user’s consent.  Specifically, we will use or share a user’s information as detailed below.  However, please note that we do not control whether any third parties, including intermediaries or program sponsors who use the Website will use data that it maintains in a portal for marketing or advertising purposes.  

With a user’s consent. We may share a user’s information with third parties if a user has provided us with the consent to do so.  

To provide users with products, services and access to content. We may use user information to allow you to participate in interactive features on our Website, to support application materials, and to use services and services through the Website and/or portals.  Users may have access to the information on the Website or specific portals that is appropriate to his/her user identity through the use of appropriate access controls.  

To communicate with users. We use a user’s data to send the user information about the IPC and its services, to respond to the user when a user contacts us for support services, to verify a user or its account, or for other communication reasons, as needed.  

With third party service providers performing services on our behalf. We may share information with our third-party service providers or partners to perform the functions for which we engage or partner with them. We may share information as needed to operate other related services.  For example, we may share information about a user with the Website or portal developer, with third parties who assist us with our error monitoring, and with our cloud servers and third-party storage providers.   

To improve and personalize the Website and the products and services IPC provides. We use the information we collect to improve and personalize the products and services that IPC provides to you.   

To create anonymous data. We may remove all identifying information from a user’s data to create anonymous data and aggregate that data with other anonymous data. We may disclose and sell this aggregated, anonymous information without restriction. 

With advertisers. We do not share or sell a user’s information for advertising purposes.   

For data aggregation. We may use reports or export aggregated data from the Websites to analyze for our own purposes.  

For corporate transactions. We may share some or all of a user’s information in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets.  In the event of an insolvency, bankruptcy, or receivership, we may transfer a user’s information as a business asset. If another company acquires our company, business, or assets, that company will possess the information we collected and will assume the rights and obligations regarding a user’s information as described in this Privacy Notice. 

To investigate suspicious activity. We may use a user’s company name, name, email, phone number or other information tied to a user in order to investigate any suspicious activity associated with such account or use.  

For legal purposes. We may preserve or disclose information about a user to comply with a law, regulation, legal process, or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, or threats to the security of the Website or any products or services or the physical safety of any person. 

Legal Basis for Processing Users’ Information 

We will only use a user’s identifiable personal data when the law allows us to.  Most commonly, we will use a user’s personal data in the following circumstances: 

• Where it is necessary for us to provide services to a user, our legal basis for processing the user’s information is our legitimate interests (or those of a third party) so long as the user’s interests and fundamental rights do not override our interests; 
• Where we need to perform the contract we are about to enter into or have entered into with a user; 
• Where we need to comply with a legal or regulatory obligation; or 
• When we have a user’s clear and unambiguous consent. 

A User’s Options Regarding Such User’s Information  

Opt-Out. We may periodically send our users free newsletters and e-mails to the e-mail address that users provided to us that directly promote the use of the Company, our Website or services we provide.  A user may indicate a preference to stop receiving further communications from us and a user will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail the user receives or by contacting us at info@inclusiveteam.org and requesting to be removed from future communications.  Despite a user’s indicated e-mail preferences, we may send a user service-related communications, including notices of any updates to our Privacy Notice.   

Cookies. If a user decides at any time that they no longer wish to accept Cookies from the Website or related services for any of the purposes described above, the user may be able to change the user’s browser settings so that it stops accepting Cookies, or to prompt the user before accepting a Cookie from the websites the user visits. Users should consult their browser’s technical information for additional information. If a user does not accept Cookies, however, such user may not be able to use all portions of the Website or have all functionality of the services IPC provides.   

Changing/Deleting a User’s Information. Our services collect critical information to keep track of information required to review, approve and fulfill green energy improvements on behalf of homeowners, contractors and lenders.  This information is stored for historical record keeping and government reporting.  

Your California and Other State Privacy Rights 

Please note: These rights may not apply to information on our Website collected from customers of a financial institution, e.g., individual borrowers.  That information is governed by federal privacy laws. If you are accessing the Website and related services through a lender, please contact your lender for more information on the applicable privacy regulations.  

Where applicable residents of California or, where and when applicable, Connecticut, Colorado, Utah, or Virginia, may have the following rights with respect to your personal information.   

• The right to know what categories or specific personal information we have collected, used, disclosed, and sold about you. To submit a request to know, you may contact us as described above under How to Contact Us. You also may designate an authorized agent to make a request for access on your behalf. 
• The right to request that we correct inaccurate personal information that we maintain about you. To submit a request for correction, you may contact us as described above under How to Contact Us. You may also designate an authorized agent to make a request for correction on your behalf.   
• The right to request that we delete any personal information we have collected about you. To submit a request for deletion, you may contact us as described above under How to Contact Us. You also may designate an authorized agent to make a request for deletion on your behalf. 
• You have the right to opt-out of the sale of your personal information or the sharing of your personal information for cross-context advertising—however, the Company does not sell or share your personal information (and has not done so for the 12-month period prior to the effective date of the Privacy Notice) as we understand the requirements of applicable law. 

When you exercise these rights and submit a request to us, we will verify your identity by asking you to log in to your account if you have one with us. If you do not have an account with us, we may ask for information such as your email address, order numbers of your previous orders, the last four digits of a credit or debit card or a bank account number used to make a purchase, or the date of your last purchase. We also may use a third-party verification provider to verify your identity. 

You have the right to appeal any decision or action that we take related to the above-described privacy rights. If you believe that the Company has failed to take appropriate action in response to your privacy rights request or you believe that we have denied your request improperly, you may appeal by contacting us as described above under How to Contact Us.  

Your exercise of these rights will have no adverse effect on the price and quality of our goods or services. 

If you are a California resident, you may request information about our disclosure of personal information to third parties or affiliated companies for their direct marketing purposes. To make such a request, please contact us as set forth in the “Contact Us” section below. Please allow up to 30 days for us to process your request. You may submit such a request once (1) per year. 

Data Retention 

We retain the personal information we collect for as long as needed to provide and improve the Services and for government record keeping purposes. We will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements with users, and/or the period required by laws in applicable jurisdictions.  

Information Security 

We use a combination of technical, administrative, and physical controls to maintain the security of users’ data. If a user has a security-related concern, please contact us.  Users should always be sure to secure their login credentials for on-line access to the Website. In order to protect our users and the information on the Website, we may suspend a user’s use of any of the related services, without notice, pending an investigation, if we suspect any breach of security.   

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website. 

Children’s Privacy  

Our Website is not intended for use by children. Children under thirteen (13) should not send any information about themselves to us. We do not collect personally identifiable data from any person that we know to be under the age of thirteen (13). If we learn that a child under thirteen (13) has submitted information to us through any part of the Website, we will attempt to delete this information as soon as practical. 

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights for more information. 

Changes to this Privacy Notice 

We reserve the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will post the updated notice on the Website and update the notice’s effective date. Users are responsible for periodically visiting the Website to check for updates to the Privacy Notice. A user’s continued use of the Website following the posting of changes constitutes such user’s acceptance of the changes.