Privacy Policy

Your privacy is critically important to us. At NewCarbon, we have a few fundamental principles:

We are thoughtful about the personal information we ask you to provide and the personal information that we collect about you through the operation of our services.
We store personal information for only as long as we have a reason to keep it.
We aim to make it as simple as possible for you to control what information on your website is shared publicly (or kept private), indexed by search engines, and permanently deleted.
We help protect you from overreaching government demands for your personal information.
We aim for full transparency on how we gather, use, and share your personal information.

Below is our Privacy Policy, which incorporates and clarifies these principles.

1. Who We Are and What This Policy Covers

NewCarbon Business Services, LLC, its affiliates, and parent companies (“NewCarbon,” “we,” “our,” “us) is a clean energy infrastructure company who develops, owns and operates infrastructure that delivers lifecycle carbon intensity reduction for industrial, agricultural and municipal organizations in the Midwest. NewCarbon’s turnkey infrastructure process makes it easier for you to reduce lifecycle carbon intensity so your organization can remain focused on what it does best.

This Privacy Policy explains what information we collect, why we collect it, how we use it, and the rights you may have under U.S. law.

This Privacy Policy applies to information that we collect about you when you use:

Our website (https://www.newcarbon.energy)
Our mobile applications
Our other NewCarbon products, services, and features that are available on or through our website

Some features described below may not be active today; we describe them to explain how we will handle information if and when those features are offered.

This Privacy Policy also applies to information we collect when you apply for a job at NewCarbon.

Throughout this Privacy Policy we’ll refer to our website, mobile applications, and other products and services collectively as “Services.”

Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.

2. What Information We Collect and Why We Collect It

We only collect information about you if we have a reason to do so — for example, to provide our Services, to communicate with you, or to make our Services better.

We collect this information from three sources: if and when you provide information to us, automatically through operating our Services, and from outside sources. Let’s go over the information that we collect.

3. Information You Provide to Us

It’s probably no surprise that we collect information that you provide to us directly. Here are some examples:

Contact Information: Name, email, phone number, address, record of purchases you’ve made
Payment Information: We may collect payment information (including credit‑card details) if e‑commerce features are enabled. We do not currently store full credit‑card numbers on our servers.
Utility Information: Utility account numbers, Copies of utility bills, Energy usage history, Account-holder identity
Project Information: Site photos, engineering files, system specifications, roof drawings
Identity Verification Materials: Driver’s license, Government‑issued ID, Deeds or ownership records
Financial Information: Information relevant to project economics, billing history, cost‑share documentation, and interconnection fees
Credit‑Related Information: Credit check authorization, Credit score results provided by third‑party bureaus (FCRA‑regulated)
E‑Signature Information: Signed agreements, IP address, device information, and timestamps generated during signing
Uploaded Documents: Any artifacts you upload to support eligibility, property verification, contractor engagement, or regulatory processes
Content information: If you leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
Communications with us (hi there!): You may also provide us with information when you respond to surveys or contact forms, communicate with us about a support question, post a question in our public forums, sign up to receive updates about products and promotions or subscribe to our mailing list. When you communicate with us via form, email, phone, comment, or otherwise, we store a copy of our communications (including any call recordings as permitted by applicable law).
Job applicant information: If you apply for a job with us — awesome! You may provide us with information like your name, contact information, resume or CV, and work authorization verification as part of the application process.

4. Information We Collect Automatically

We also collect some information automatically:

Log information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, including the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services.
Usage information: We collect information about your usage of our Services. For example, we collect information about what happens when you use our Services (e.g., page views, hyperlink clicks, abandoned cart statistics and interactions with our Services) along with information about your device (e.g., screen size, name of cellular network, and mobile device manufacturer). We use this information to, for example, provide our Services to you, get insights on how people use our Services so we can make our Services better, and understand and make predictions about user retention.
Location information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions. We may also collect information about your precise location via our mobile apps (like when you post a photograph with location information) if you allow us to do so through your mobile device operating system’s permissions.
Stored information: We may access information stored on your mobile device via our mobile apps. We access this stored information through your device operating system’s permissions. For example, if you give us permission to access the photographs on your mobile device’s camera roll, our Services may access the photos stored on your device when you upload a really amazing photograph of the sunrise to your website.
Information from cookies & other technologies: A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Pixel tags (also called web beacons) are small blocks of code placed on websites and emails. We use cookies to operate the website, maintain security, measure performance, and improve user experience. We may in the future enable additional cookie categories (e.g., authentication or advertising) if the site supports those features. For more information about our use of cookies and other technologies for tracking, including how you can control the use of cookies, please see our Cookie Policy.
Embedded content from other websites: Our site may include embedded content (e.g. videos, images, articles, Google Maps, Utility portals, Contractor platforms, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website. These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website. Please note that any information you provide to the other website will be handled in accordance with the other website’s privacy policy and practices. We don’t own or control these other websites, and they have their own rules about information collection, use, and sharing, which you should review before using the software or services.

5. Information We Collect from Other Sources

Third-party services may give us information, like mailing addresses for individuals who are not yet our users (but we hope will be!). If and when we send physical mailers, we will comply with applicable direct‑mail and opt‑out requirements.

We may also receive the following as a function of our Services:

Utility data for project qualification
Interconnection status updates
Credit‑determination results (via authorized bureaus)
Engineering or site‑survey materials from contractors
Regulatory compliance documents

6. Purposes for Using Information

We use information about you for the purposes listed below:

Provide and Improve Our Services: Evaluate site feasibility and design project systems, Prepare utility interconnection applications, Validate eligibility for incentive or regulatory programs, Maintain secure customer accounts and project records, Facilitate e‑signatures, contract execution, and document management
Legal, Compliance, and Security: Comply with state and federal utility regulations, Satisfy GLBA obligations when handling financing‑adjacent information, Respect FCRA requirements when credit checks are performed, Prevent fraud and unauthorized access, Conduct audits and maintain compliance documentation
Communications: Send project updates, Provide customer service, Share legally required disclosures or regulatory notices
To ensure quality, maintain safety, and improve our Services. For example, by providing updates to our Services. Or, for example, by monitoring and analyzing how users interact with our Services so we can create new features that we think our users will enjoy or make our Services easier to use.
To market our Services and measure, gauge, and improve the effectiveness of our marketing. For example, by targeting our marketing messages to groups of our users (like those who have a particular membership plan with us or have been users for a certain length of time), advertising our Services, analyzing the results of our marketing campaigns (like how many people purchased a membership plan after receiving a marketing message), and understanding and forecasting user retention.
To protect our Services, our users, and the public. For example, by detecting security incidents; detecting and protecting against malicious, deceptive, fraudulent, or illegal activity; fighting spam; complying with our legal obligations; and protecting the rights and property of NewCarbon and others, which may result in us, for example, declining a transaction or terminating Services.
To fix problems with our Services. For example, by monitoring, debugging, repairing, and preventing issues.
To customize the user experience. For example, to personalize your experience by serving you customized content and advertisements for our Services.
To communicate with you. For example, by emailing you to ask for your feedback, share tips for getting the most out of our Services, or keep you up to date on NewCarbon; texting you to verify your payment; or calling you to share offers and promotions that we think will be of interest to you. If you don’t want to hear from us, you can opt out of marketing communications at any time. (If you opt out, we’ll still send you important updates relating to your account.)
To recruit and hire new employees. For example, by evaluating job applicants and communicating with them.

7. Legal Bases for Collecting and Using Information

Because NewCarbon operates only within the United States, we comply with U.S. federal and state laws applicable to sensitive data in the energy and financial sectors.

GLBA (Financial Information): If you apply for financing, provide financial documents, or request a cost‑benefit analysis that uses financial data, we treat that information consistent with GLBA standards for safeguarding.

FCRA (Credit Information): If you authorize a credit check: (1) We use the results only for the purpose of evaluating project eligibility or financing viability, and (2) You may request the source of the information and dispute inaccuracies.

State Utility Privacy Requirements: Some utilities restrict how customer usage data and account numbers may be stored, transmitted, or reused. We adhere to those requirements.

8. How We Share Information

We share information about you in limited circumstances, and with appropriate safeguards on your privacy. These are spelled out below, as well as in the section called Ads and Analytics Services Provided by Others:

Subsidiaries and independent contractors: We may disclose information about you to our subsidiaries and independent contractors who need the information to help us provide our Services or process the information on our behalf. We require our subsidiaries and independent contractors to follow this Privacy Policy for any personal information that we share with them.
Third-party vendors: We may share information about you with third-party vendors who need the information in order to provide their services to us, or to provide their services to you. This includes vendors that help us provide our Services to you (like Stripe payment providers that process your credit and debit card information, fraud prevention services that allow us to analyze fraudulent payment transactions, cloud storage services, postal and email delivery services that help us stay in touch with you, customer chat and email support services that help us communicate with you); those that assist us with our marketing efforts (e.g., by providing tools for identifying a specific marketing target group or improving our marketing campaigns, and by placing ads to market our services); those that help us understand and enhance our Services (like analytics providers); those that make tools to help us run our operations (like programs that help us with task management, scheduling, word processing, email and other communications, and collaboration among our teams); other third-party tools that help us manage operations; Utilities (interconnection, verification, and eligibility); Contractors performing site visits or engineering; Credit‑check vendors (only if you authorize); Regulatory bodies requiring documentation; Vendors performing document storage, e‑signature services, or secure hosting; Professional advisers (legal, auditing, compliance); and companies that make products available on our Services, who may need information about you in order to, for example, provide technical or other support services to you. We require vendors to agree to privacy commitments in order to share information with them.
Legal and regulatory requirements: We may disclose information about you in response to a subpoena, court order, or other governmental request.
To protect rights, property, and others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of NewCarbon, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.
Business transfers: In connection with any merger, sale of company assets, or acquisition of all or a portion of our business by another company, or in the unlikely event that NewCarbon goes out of business or enters bankruptcy, user information would likely be one of the assets that is transferred or acquired by a third party. If any of these events were to happen, this Privacy Policy would continue to apply to your information and the party receiving your information may continue to use your information, but only consistent with this Privacy Policy.
With your consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties when you authorize us to do so.
Aggregated or de-identified information: We may share information that has been aggregated or de-identified, so that it can no longer reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services, or share a hashed version of your email address to facilitate customized ad campaigns on other platforms.
Published support requests: If you send us a request for assistance (for example, via a support email or one of our other feedback mechanisms), we reserve the right to publish that request in order to clarify or respond to your request, or to help us support other users.

We have a long-standing policy that we do not sell our users’ data. We aren’t a data broker, we don’t sell your personal information to data brokers, and we don’t sell your information to other companies that want to spam you with marketing emails.

9. Information Shared Publicly

Information that you choose to make public is — you guessed it — disclosed publicly. That means information like comments that you post on our Services. Please keep all of this in mind when deciding what you would like to share publicly.

10. How Long We Keep Information

We retain information: For as long as a project is active, For required regulatory retention periods (e.g., loans, contracts, interconnection documents), For compliance and audit purposes.

Otherwise, we generally discard information about you when it’s no longer needed for the purposes for which we collect and use it — described in the section above on How and Why We Use Information — and we’re not legally required to keep it. You may request deletion when legally permissible.

11. Security

While no online service is 100% secure, we work hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so.

We maintain safeguards informed by NIST Cybersecurity Framework principles, including:

Encryption in transit and at rest
Access controls and least‑privilege role permissions
Logging, monitoring, and audit trails
Vendor risk assessment and contractual data‑protection standards

12. Choices

You have several choices available when it comes to information about you:

Limit the information that you provide: If you have an account with us, you can choose not to provide the optional account information, profile information, and transaction and billing information. Please keep in mind that if you do not provide this information, certain features of our Service will not be accessible.
Limit access to information on your mobile device: Your mobile device operating system should provide you with the option to discontinue our ability to collect stored information or location information via our mobile apps. If you choose to limit this, you may not be able to use certain features, like geotagging for photographs.
Opt out of marketing communications: You may opt out of receiving promotional communications from us. Just follow the instructions in those communications or let us know. If you opt out of promotional communications, we may still send you other communications, like those about your account and legal notices.
Set your browser to reject cookies: At this time, NewCarbon does not respond to “do not track” signals across all of our Services. However, you can usually choose to set your browser to remove or reject browser cookies before using the NewCarbon website, with the drawback that certain features of the NewCarbon website may not function properly without the aid of cookies.
Close your account: While we’d be very sad to see you go, you can close your account if you no longer want to use our Services. Please keep in mind that we may continue to retain your information after closing your account, as described in How Long We Keep Information above — for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests.

13. Your Rights

If you are located in certain parts of the United States, including California, you may have certain rights regarding your personal information, like the right to request access to or deletion of your data.

14. California Consumer Privacy Act (CCPA)

The California Consumer Privacy Act (“CCPA”) requires certain websites to provide California residents with some additional information about the categories of personal information that is collected and shared, where the website get that personal information, and how and why the website uses that personal information. While Cognitive Concierge currently does not exceed any of the current CCPA thresholds and are thus not obligated to comply with the CCPA requirements, we do generally strive to satisfy the requirements of the CCPA as a matter of principle.

The CCPA requires websites to provide a list of the “categories” of personal information that is collected, as that term is defined in the law, so. In the last 12 months, Cognitive Concierge collected the following categories of personal information from California residents, depending on the Services used:

Identifiers (like your name, contact information, and device and online identifiers);
Commercial information (your billing information and purchase history, for example);
Characteristics protected by law (for example, you might provide your gender as part of a research survey for us);
Internet or other electronic network activity information (such as your usage of our Services);
Geolocation data (such as your location based on your IP address);
Audio, electronic, visual or similar information (such as your profile picture, if you uploaded one);
Professional or employment-related information (for example, your company and title, or information you provide in a job application); and
Inferences we make (such as likelihood of retention or attrition).

You can find more information about what we collect and sources of that information in the Information We Collect section above.

We collect personal information for the business and commercial purposes described in the How and Why We Use Information section. And we share this information with the categories of third parties described in the Sharing Information section above.

If you are a California resident, you have additional rights under the CCPA, subject to any exemptions provided by the law, including the right to:

Request to know the categories of personal information we collect, the categories of business or commercial purpose for collecting and using it, the categories of sources from which the information came, the categories of third parties we share it with, and the specific pieces of information we collect about you;
Request deletion of personal information we collect or maintain;
Opt out of any sale of personal information; and
Not receive discriminatory treatment for exercising your rights under the CCPA.

We may show ads on some parts of our website as part of our advertising program. As part of any future advertising program, we may use cookies to share certain device identifiers and information about your browsing activities with our advertising partners, and those advertising partners may use that information to show you personalized ads on some parts of our website.

The personal information we share includes online identifiers; internet or other network or device activity (such as cookie information, other device identifiers, and IP address); and geolocation data (approximate location information from your IP address). These disclosures may be considered a “sale” of information under the CCPA. We do not sell (or share) information through our ads program that identifies you personally, like your name or contact information. We don’t knowingly sell personal information of those under 16.

15. Ads and Analytics Services Provided by Others

Ads appearing on any of our Services may be delivered by advertising networks. Other parties may also provide analytics services via our Services. These ad networks and analytics providers may set tracking technologies (like cookies) to collect information about your use of our Services and across other websites and online services. These technologies allow these third parties to recognize your device to compile information about you or others who use your device. This information allows us and other companies to, among other things, analyze and track usage, determine the popularity of certain content, and deliver ads that may be more targeted to your interests. Please note this Privacy Policy only covers the collection of information by NewCarbon and does not cover the collection of information by any third-party advertisers or analytics providers.

16. Children’s Privacy

Our services are not intended for children under 18. We do not knowingly collect information from individuals under 18.

17. Changes

Although most changes are likely to be minor, NewCarbon may change its Privacy Policy from time to time. NewCarbon encourages visitors to frequently check this page for any changes to its Privacy Policy. In some cases, we may provide notice that we made changes to this Privacy Policy (like adding a statement to our website or sending you a notification through email). Your further use of the Services after a change to our Privacy Policy will be subject to the updated policy.

18. Contact

You can usually access, correct, or delete your personal data using your account settings and tools that we offer, but if you aren’t able to or you’d like to contact us about one of the other rights, scroll down to the Contact Us section at the bottom of our website to find out how to reach us.

When you contact us about one of your rights under this section, we will take reasonable steps to verify your identity. This may include confirming your email address, matching information you previously provided (e.g., utility account details or project documents), requesting proof of identity, or requiring a signed authorization.

19. Reference

This Privacy Policy is a derivative of “Privacy Policy” by Automattic licensed under CC BY-SA 4.0.

Last Updated: January 1, 2026