Privacy Policy

This Privacy Notice for Balto Energy, Inc. ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

• Visit our website at https://baltoenergy.com or any website of ours that links to this Privacy Notice
• Engage with us in other related ways, including any marketing or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at privacy@baltoenergy.com.

Summary of Key Points

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? Balto's website collects home owner information — homeowners provide details about their home, energy bills, equipment, and goals so that we and our operating company can evaluate eligibility for residential energy financing and installation. We process the home owner information you provide, plus standard website-usage information.

Do we share your information with our operating company? Yes — information you submit through Balto is shared with our operating company, Northern Pacific Power Systems (NPP), a licensed installer of solar and battery equipment, who uses it to evaluate eligibility, prepare quotes, and arrange installation. This sharing is the operational purpose of the website. Learn more in section "When and with whom do we share your personal information?" below.

Do we process any sensitive personal information? Some of the information may be considered "special" or "sensitive" in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law.

Do we collect any information from third parties? We may collect limited information from public databases and other outside sources.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties.

How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the Privacy Notice in full below.

Table of Contents

1. What information do we collect?
2. How do we process your information?
3. When and with whom do we share your personal information?
4. What is our stance on third-party websites?
5. Do we use cookies and other tracking technologies?
6. Artificial intelligence processing
7. How long do we keep your information?
8. How do we keep your information safe?
9. Do we collect information from minors?
10. What are your privacy rights?
11. Controls for do-not-track features
12. Do United States residents have specific privacy rights?
13. Third-party counterparty data
14. Energy services and customer records retention
15. Do we make updates to this notice?
16. How can you contact us about this notice?
17. How can you review, update, or delete the data we collect from you?

1. What Information Do We Collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us, primarily as home owner information you submit on our Site about your home, energy bills, equipment, and energy goals. We share this information with our operating company, Northern Pacific Power Systems (NPP), so they can evaluate eligibility and prepare a quote.

The Site collects home owner information about your home, your energy usage, your equipment, and your goals. We use the home owner information you submit — together with other information you voluntarily provide when you register, request information, or contact us — to (a) assess whether and how we may be able to provide financing for residential energy equipment at your site and (b) share with our operating company, NPP, who uses it to prepare a quote and arrange installation.

Personal Information Provided by You. The personal information that we collect depends on the home owner information you provide and the context of your other interactions with us. The personal information we collect may include the following:

• names
• email addresses
• mailing addresses (including service-address / installation-site address)
• phone numbers
• usernames
• passwords
• contact preferences
• contact or authentication data
• utility account holder name, utility account number, utility provider name, and electric meter ID
• household and site information collected during the quote process, including service-address location, roof characteristics (roof-face areas, azimuth, pitch, orientation), aerial / satellite imagery of your property, solar insolation data, existing equipment information, and shading analyses
• utility bill content and metadata

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

• utility account credentials or OAuth authorization — collected only if you choose to connect your utility account through a utility-data provider or your utility's direct authorization (OAuth). Connecting your utility account is currently optional.
• chat messages and conversation content you submit through any chat features on the Site, including the context surrounding your messages (e.g., relevant scenario, equipment, or cost information you and we are discussing)
• precise geolocation data — calculated by geocoding the service address you provide. We do not access your device's GPS or other on-device location signals.

Balto does not initially collect payment information through the Site. Any payment for energy services or financing happens through the operating company or other channels outside this Site, and is governed by the customer agreement(s) you separately execute with the relevant party.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

We use a privacy-friendly, cookieless web-analytics tool to measure aggregate usage of the Site (such as page views and referrers). It does not set cookies, store cross-site identifiers, or track you across other websites.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

Information collected from other sources

In Short: We may collect limited data from public databases and other outside sources.

We may obtain limited information about you from outside sources to maintain accurate records and support the services you request. For example, we may use public solar, weather, and climate datasets to generate solar production estimates and equipment-fit analyses tied to the service address you provide. These sources are queried using the service address or coordinates only — no personally identifiable home owner information is sent to them.

2. How Do We Process Your Information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts.
• To deliver and facilitate delivery of services to the user.
• To respond to user inquiries/offer support to users.
• To send administrative information to you.
• To request feedback.
• To send you marketing and promotional communications. You can opt out of our marketing emails at any time. For more information, see "What are your privacy rights?" below.
• To protect our Services. Including fraud monitoring and prevention.
• To evaluate and improve our Services, products, marketing, and your experience.
• To identify usage trends.
• To comply with our legal obligations.
• To share home owner information with our operating company, NPP, for quote generation and installation. Home owner information you submit through the Balto Site — including your name, contact information, service address, household and site information, energy bills, equipment information, and energy goals — is shared with Northern Pacific Power Systems (NPP) so that NPP can evaluate eligibility, prepare a quote, and arrange installation by licensed contractors. This sharing is a primary operational purpose of Balto's website and is not optional if you wish to receive a quote or installation through Balto.
• To evaluate financing eligibility. We use personal information you provide (including home owner information, household/site data, and energy usage information) to evaluate whether and how Balto may be able to provide financing for residential energy equipment at your site. Any financing relationship is established only through a separately-executed customer agreement.
• Counterparty communications. We use personal information to facilitate communications with counterparties involved in your project, including utility providers, partner operating companies, licensed contractors, registered agents, and other parties whose participation is required to complete the workflow you initiated.
• To power AI-assisted chat features. We use personal information you submit through chat — including your messages and relevant context about your home, energy goals, and scenario data we have collected — together with third-party AI services (OpenAI and Anthropic) to provide chat responses, recommendations, and analyses. See Section 6 for more on AI processing.
• Use of data for AI training. We do not use the specific contents of your chat messages, utility bills, or other sensitive home owner information you submit to train AI models without your explicit written consent.
• To analyze and improve our Services. We use personal information — together with aggregated, de-identified usage data — to understand how the Site is used, evaluate the effectiveness of our offerings, and improve our Services. We do not sell your personal information to third parties.

3. When and With Whom Do We Share Your Personal Information?

In Short: We share home owner information you submit through the Balto Site with our operating company, Northern Pacific Power Systems (NPP), so they can prepare a quote and arrange installation. We also share information with the categories of third parties listed below.

Northern Pacific Power Systems (NPP) — our operating company. Home owner information you submit through the Balto Site — including your name, contact information, service address, household and site information, energy bills, equipment information, and energy goals — is shared with NPP so that NPP can evaluate eligibility, prepare a quote, and arrange installation by licensed contractors. NPP's own use of the information you provide through Balto is governed by NPP's privacy practices, which you can review at https://www.northernpacificpower.com/privacy-policy/.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information.

The categories of third parties we may share personal information with include:

• Data analytics and storage providers — we store and analyze home owner information and operational data collected through the Site using our data platform provider(s).
• Customer relationship management (CRM) providers — home owner information you submit through the Site flows into CRM records used by Balto and by NPP to manage your inquiry, quote, and any subsequent project work.
• Cloud hosting and infrastructure providers — our hosting and edge-infrastructure providers process and store personal information you submit through the Site; requests to baltoenergy.com pass through their infrastructure.
• Honeycomb — service-monitoring and analytics (observability) provider. Honeycomb receives technical telemetry from the Site — including request metadata, error reports, and performance traces — which may include limited user-related identifiers (such as IP addresses or session identifiers) for diagnostic and service-analytics purposes. This is server-side telemetry, not a browser cookie or cross-site tracking.
• Authentication providers — if you create an account, our authentication provider receives your email and credentials to manage your authenticated session.
• Email and communications providers — these providers handle email sent to and from Balto contact addresses (such as privacy@baltoenergy.com) and any transactional or support communications you receive from us.
• Mapping and geocoding providers — when you provide a service address, a mapping/geocoding provider receives that address so we can derive the latitude/longitude coordinates of your property for site-specific analyses (such as shading and equipment-fit calculations).
• Solar design and quote-generation providers — these providers process site-and-roof information about your property (including aerial / satellite imagery, roof characteristics, and solar insolation data) to support quote generation and project design.
• Utility-data providers — if you choose to connect your utility account, a utility-data provider (or your utility's direct authorization service) receives the credentials you supply and returns your utility-account data to us. Connecting your utility account is currently optional.
• Electricity-tariff and bill-calculation providers — these providers may receive utility-account information needed to compute applicable tariffs and bill projections.
• OpenAI and Anthropic — third-party AI service providers. If you use chat or other AI features, OpenAI and Anthropic receive your chat messages and the relevant home owner / scenario context needed to generate a response. See Section 6.

We do not use third-party advertising networks, and we do not share your personal information for cross-context behavioral advertising.

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Licensed contractors. Where installation services are arranged on your behalf, NPP or Balto may share information with the licensed contractor(s) actually performing the installation and ongoing service work.

4. What Is Our Stance on Third-Party Websites?

In Short: We are not responsible for the safety of any information that you share with third parties that we may link to but are not affiliated with our Services.

The Services may link to third-party websites, online services, or mobile applications that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third-party websites. Any data collected by third parties is not covered by this Privacy Notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.

5. Do We Use Cookies and Other Tracking Technologies?

In Short: We use cookies and similar technologies only as needed to operate the Site and remember your preferences.

We use strictly-necessary, first-party cookies and similar technologies (such as local storage) to maintain the security of our Services, remember your preferences, and support basic site functions. We do not use advertising or cross-site tracking cookies on the Site, and we do not sell or share your personal information for cross-context behavioral advertising.

Specific information about the cookies and local storage we use, and how you can manage them, is set out in our Cookie Notice.

6. Artificial Intelligence Processing

In Short: We use third-party AI services (OpenAI and Anthropic) to power chat features and related AI-assisted analyses. We do not train AI models on your specific home owner information without your explicit consent.

We offer chat features and related AI-assisted analyses on the Site (collectively, "AI Features"). AI Features rely on third-party AI service providers — currently OpenAI and Anthropic.

When you use an AI Feature, your input (chat messages, questions, and the context surrounding them) and the relevant home owner information needed to provide a response (such as your service address, energy goals, equipment information, and scenario data we have collected) is transmitted to the AI service provider for processing. AI service providers process your input under their own terms of service and privacy practices, and may retain inputs and outputs for the purposes described in their respective terms.

No training on your content without consent. We do not use the specific contents of your chat messages, utility bills, or other sensitive home owner information you submit to train AI models without your explicit, separate written consent. If we wish to use such content for AI training purposes, we will request your affirmative consent before doing so, and you may decline without losing access to non-AI features of the Site.

Opt out. You may request to opt out of AI-assisted processing by contacting us at privacy@baltoenergy.com. Note that opting out may limit or disable certain AI Features.

7. How Long Do We Keep Your Information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. How Do We Keep Your Information Safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

9. Do We Collect Information From Minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at privacy@baltoenergy.com.

10. What Are Your Privacy Rights?

In Short: You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "How can you contact us about this notice?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section "How can you contact us about this notice?" below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. For further information, please see our Cookie Notice.

If you have questions or comments about your privacy rights, you may email us at privacy@baltoenergy.com.

11. Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

Global Privacy Control: We recognize and honor Global Privacy Control (GPC) signals. If you use a browser or extension that supports GPC, we will treat this as a valid request to opt out of the sale or sharing of your personal information for targeted advertising purposes under applicable state privacy laws, including the California Consumer Privacy Act (CCPA). When we detect a GPC signal from your browser, we will automatically apply your opt-out preference without requiring you to take any additional action. For more information about GPC and how to enable it, visit globalprivacycontrol.org.

12. Do United States Residents Have Specific Privacy Rights?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect

The table below shows the categories of personal information we have collected. The table includes illustrative examples of each category and does not reflect the entirety of personal information we collect from you. For a comprehensive inventory, please refer to "What information do we collect?" above.

We only collect sensitive personal information, as defined by applicable privacy laws or for the purposes allowed by law or with your consent. Sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You may have the right to limit the use or disclosure of your sensitive personal information.

We will use and retain the collected personal information as needed to provide the Services or for:

• Category A (Identifiers) — As long as the user has an account with us, plus any longer period required for energy services records (see Section 14)
• Category B (CCRA personal information) — As long as the user has an account with us, plus any longer period required for energy services records
• Category F (Internet / network activity) — As long as the user has an account with us
• Category G (Geolocation) — As long as the user has an account with us
• Category K (Inferences) — As long as the user has an account with us
• Category L (Sensitive personal information) — As long as the user has an account with us, subject to additional consent requirements

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

Depending upon the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)
• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)
• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)
• Right to obtain a list of third parties to which we have sold personal data (as permitted by applicable law, including the privacy law in Connecticut)
• Right to review, understand, question, and depending on where you live, correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Connecticut and Minnesota)
• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)
• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)

How to Exercise Your Rights

To exercise these rights, you can contact us by submitting a data subject access request, by emailing us at privacy@baltoenergy.com, or by referring to the contact details at the bottom of this document.

We will honor your opt-out preferences if you enact the Global Privacy Control (GPC) opt-out signal on your browser.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at privacy@baltoenergy.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine The Light" Law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section "How can you contact us about this notice?"

13. Third-Party Counterparty Data

Balto facilitates communications and project workflows on behalf of homeowners ("our users"). In the course of providing these services, we may collect, process, and transmit personal information of individuals who are not registered users of our platform, including but not limited to utility-account holders, partner operating company employees, licensed installer-contractors, registered agents, and other counterparties involved in the homeowner's project. Personal information collected about such counterparties may include names, email addresses, mailing addresses, phone numbers, signature data, title or role, and company affiliation. This information is collected and processed solely for the purpose of completing workflows initiated by our users, such as solar / battery quote requests, utility-side authorizations, project scheduling, and contractor coordination. Counterparties whose personal information is processed through our platform may contact us at privacy@baltoenergy.com to request access to, correction of, or deletion of their personal information, subject to any applicable legal retention obligations.

14. Energy Services and Customer Records Retention

Balto maintains homeowner-account data, project history, and energy services records. Because these records may have ongoing legal and operational significance — including for warranty claims, utility-side disputes, and tax-related documentation — our data retention practices may differ from those of general consumer software platforms. We retain personal information associated with active user accounts for as long as an account remains open. Users may submit a data deletion request at any time by contacting privacy@baltoenergy.com. Deletion requests will be honored to the extent permitted by applicable law, and we will notify you if any portion of your data must be retained to satisfy legal, regulatory, or warranty obligations.

15. Do We Make Updates to This Notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

16. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may email us at privacy@baltoenergy.com or contact us by post at:

Balto Energy, Inc. 1501 Summit Ave Cardiff by the Sea, California 92007 United States

17. How Can You Review, Update, or Delete the Data We Collect From You?

You have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please fill out and submit a data subject access request, or contact us at privacy@baltoenergy.com.