PRIVACY POLICY

Article 1 — Scope; Company Role

I. Policy. This Privacy Policy describes how Utility Switch LLC (“Company,” “we,” “us,” or “our”) collects, uses, discloses, retains, and protects personal information in connection with our utility switching, account-coordination, and move-concierge support services (the “Services”), websites, communications, and related operations.

II. Persons covered. This Privacy Policy applies to Customers, prospective Customers, Authorized Signers and other persons legally authorized to act on a Customer’s behalf, account users, household contacts, persons whose information is submitted to Company in connection with the Services, website visitors, and persons who otherwise communicate with Company.

III. Adults. The Services are intended for persons 18 years of age or older and are not directed to children. Company does not knowingly collect personal information directly from a child for purposes of establishing a Customer relationship. An adult Customer or Authorized Signer may provide limited information concerning household members where reasonably necessary to perform the Services.

IV. Provider privacy practices. Providers and third parties have their own privacy practices. Company is not responsible for the privacy, security, accuracy, or data-handling practices of Providers or other third parties.

Article 2 — Personal Information Collected

I. Identifiers and contact information. Company may collect name, alias, signature, service address, prior address, mailing address, email address, telephone number, date of birth, household contact information, service preferences, and, for an Authorized Signer, information reasonably necessary to identify the Authorized Signer and verify the nature and scope of such person’s authority.

II. Move and service information. Company may collect move-in date, move-out date, occupancy status, service preferences, Provider selections, utility account numbers, premises identifiers, meter information, billing address, prior Provider information, requested start or stop dates, appointment preferences, and Provider communications.

III. Identity-verification information. Certain Providers may require identity-verification information, which may include date of birth, partial or full Social Security number, government-issued identification information, or other verification information. Company will seek to minimize its collection and retention of sensitive identity-verification information and, where reasonably available, may direct Customer to provide such information directly to the applicable Provider or an approved verification vendor. If Company or a third-party service provider acting on Company’s behalf receives sensitive identity-verification information to perform the requested Services, Company may use and disclose that information solely as reasonably necessary to complete the applicable verification or Service request and will retain it only as reasonably necessary for that purpose or as required by law.

IV. Property-related information. Company may collect lease, ownership, association, landlord, property-manager, builder, closing, occupancy, access, meter-location, or property-contact information reasonably necessary to coordinate utility service.

V. Payment information. Payments for Company Fees are processed directly by Company's third-party payment processor. Company does not directly collect or store Customer's complete payment-card numbers, card security codes, or bank-account credentials. Company may receive and retain limited transaction information made available by its payment processor, including payment status, transaction identifiers, payment method type, limited payment details, and records of refunds, returned payments, or payment disputes.

VI. Communications and records. Company may collect and retain emails, text messages, chat communications, voicemails, call logs, Provider communications, service notes, Customer instructions and approvals, and records relating to performance of the Services. Company may record or monitor telephone calls only after providing any notice or obtaining any consent required by applicable law, as further described in the Customer Terms of Service.

VII. Technical information. Company may collect device, browser, IP address, log, session, usage, and similar technical information in connection with the Services. Company also uses first-party cookies and internal tracking technologies to assign anonymous visitor identifiers, count visits, and identify referral sources and promotional campaigns. Such information is used solely for internal operational, security, and reporting purposes and is not shared with referral or marketing partners.

VIII. Third-party information. Company may receive information from Providers, payment processors, verification vendors, communications vendors, electronic-signature vendors, document-storage vendors, fraud-prevention vendors, referral sources, property contacts, and customer-support vendors.

IX. Sensitive information limitation. Company seeks to limit sensitive information collection to information reasonably necessary for Services, Provider requirements, identity verification, payment processing, security, fraud prevention, compliance, or dispute resolution. Company does not request sensitive personal information that is not reasonably necessary to provide the Services or satisfy applicable legal, security, or Provider requirements.

X. Representative-Authority Documentation. If a person acts on behalf of Customer, Company may collect copies of powers of attorney, guardianship documents, court orders, or other documentation reasonably necessary to verify such person’s authority. Company will use such documentation for verification, compliance, recordkeeping, fraud prevention, dispute resolution, and other purposes reasonably related to the Services and will limit disclosure of such documentation to persons with a reasonable need for access or as otherwise required or permitted by law.

Article 3 — Purposes for Use

I. Service performance. Company may use personal information to create and administer accounts, process intake forms, verify identity, coordinate utility setup, transfer, cancellation, or modification, communicate with Providers, schedule appointments, obtain status updates, provide confirmations, troubleshoot issues, and respond to support requests.

II. Customer communications. Company may use personal information to send transactional emails and provide notices through Customer's online account regarding the Services, including requests for information or documents, Provider status updates, confirmations, service completion notices, account access and password resets, invoices, receipts, support messages, and legal notices. Company may use additional communication methods if separately authorized and permitted by applicable law.

III. Payments. Company may use information to process Company Fees, administer refunds, resolve chargebacks, detect fraud, and maintain billing records.

IV. Security and fraud prevention. Company may use information to authenticate users, detect unauthorized activity, prevent fraud, protect accounts, monitor systems, investigate suspicious activity, and enforce agreements.

V. Business operations. Company may use information for training, quality assurance, analytics, product improvement, audit, accounting, tax, insurance, legal compliance, vendor management, corporate transactions, and internal administration.

VI. Marketing. Company may use contact information to provide marketing communications as permitted by applicable law. Where consent is required by law, Company will obtain the required consent before sending the applicable marketing communication. Consent to marketing communications is not a condition of purchasing the Services, and marketing preferences may be changed as described below and in the Customer Terms of Service.

Article 4 — Disclosures of Information

I. Providers. Company may disclose personal information to Providers and their agents as reasonably necessary to request, verify, initiate, transfer, cancel, modify, troubleshoot, or support utility or household-service accounts.

II. Vendors. Company may disclose or otherwise make personal information available to vendors that provide hosting, software, intake forms, electronic-signature services, document and cloud storage, customer relationship management, communications, call recording, payment processing, identity verification, fraud prevention, analytics, customer support, data storage, security, legal, accounting, insurance, and other business services.

III. Property contacts. Company may disclose limited information to landlords, property managers, associations, builders, closing coordinators, brokers, or other property contacts identified by Customer solely for utility-related verification, access, move-date, service-address, or Provider-requirement purposes.

IV. Legal and safety disclosures. Company may disclose information to comply with law, legal process, governmental requests, Provider investigations, fraud-prevention inquiries, insurance requirements, dispute resolution, enforcement of agreements, or protection of rights, safety, property, or security.

V. Corporate transactions. Company may disclose or transfer information in connection with financing, diligence, merger, acquisition, reorganization, sale of assets, bankruptcy, receivership, or transfer of business operations.

VI. Referral Partners; Campaign Attribution. Company may receive referral-source, promotional-code, and campaign-attribution information through referral links, promotional codes, or other sources to identify how Customers learned about the Services and evaluate referral and promotional programs. Such information is maintained internally and is not disclosed to referral or marketing partners.

VII. Sale and Targeted Advertising. Company does not sell personal information or share personal information with third parties for targeted advertising or cross-site behavioral advertising. Company does not use third-party advertising, remarketing, or behavioral tracking technologies.

Article 5 — Retention; Security; Incident Response

I. Retention. Company retains personal information only for as long as reasonably necessary to provide and document the Services, maintain appropriate business and transaction records, resolve disputes, prevent fraud, comply with applicable law, and establish, exercise, or defend legal claims. Company generally deletes documents and sensitive personal information collected for a particular Provider as soon as reasonably practicable after the applicable Provider confirms completion of the requested Service and such information is no longer needed for that Service. Any remaining sensitive identity-verification information and supporting Provider documents will generally be deleted upon closure of the applicable service request, including upon completion or resolution of all requested Services, revocation of the applicable authorization, a Customer request for deletion, or closure due to Customer's failure to respond to requests for information or action for sixty (60) consecutive days. A service request will not be considered inactive solely because Company is awaiting Provider action or a future scheduled move or service date. Notwithstanding the foregoing, Company will retain copies of powers of attorney and other documentation evidencing an Authorized Signer's authority for seven (7) years following closure of the applicable service request, together with the signed authorization and related verification records, or longer to the extent reasonably necessary in connection with a pending or reasonably anticipated claim, dispute, investigation, or legal hold. Company may also retain Customer account information, service addresses, transaction and payment records, service history, signed authorizations, acceptance records, and electronic-signature audit trails for business, recordkeeping, compliance, and evidentiary purposes. All retention and deletion practices are subject to applicable legal requirements, legal holds, and the deletion and backup processes of Company's service providers.

II. Disposal. Company takes reasonable measures to dispose of records containing personal information when they are no longer required to be retained, consistent with applicable law.

III. Safeguards. Company will maintain commercially reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, acquisition, destruction, use, modification, or disclosure.

IV. Security Measures. Depending on the nature of the information and applicable risks, Company may use access controls, authentication measures, vendor security controls, encryption or other transmission safeguards, logging, employee or contractor training, data minimization, and other reasonable security measures. No method of transmission or storage is completely secure, and Company cannot guarantee absolute security.

V. Security Incidents. Company maintains procedures designed to identify, evaluate, and respond to suspected security incidents involving personal information. If Company determines that notice of a security incident is required by applicable law, Company will provide notice to affected persons, governmental authorities, consumer reporting agencies, or others as required by applicable law.

Article 6 — Customer Choices and Requests

I. Access and correction. Customer may submit a request to access or correct certain personal information maintained by Company by emailing info@theutilityswitch.com. Company will respond to such requests as required by applicable law and may honor other reasonable requests in its discretion.

II. Deletion. Customer may request deletion of personal information by emailing info@theutilityswitch.com. Company will honor deletion requests to the extent required by applicable law and may retain information where reasonably necessary or permitted for purposes such as completing Services, maintaining transaction records, preventing fraud, resolving disputes, enforcing agreements, complying with law, or establishing, exercising, or defending legal claims.

III. Marketing opt out. Customer may opt out of marketing emails or texts using the instructions in the communication or by contacting Company. Company may continue sending transactional and service-related communications.

IV. Verification and Authorized Requests. Company may take reasonable steps to verify the identity and authority of a person submitting a privacy request. An Authorized Signer or other legally authorized representative may submit a request on another person’s behalf where permitted by applicable law, but Company may require documentation or other information reasonably necessary to verify the representative’s authority.

V. State-specific rights. Residents of certain states may have additional rights regarding their personal information, depending on applicable law and whether Company is subject to that law. Such rights may include rights to access, correct, delete, obtain a copy of, or opt out of certain uses or disclosures of personal information. Company will provide and honor such rights to the extent required by applicable law.

Article 7 — Cookies; Analytics; Tracking

I. Cookies and similar technologies. Company uses first-party cookies and internal tracking technologies solely for operational and internal reporting purposes, including (a) an anonymous visitor identifier retained for up to one (1) year, (b) a daily visit counter, and (c) campaign or referral-partner tags obtained through tracking links and retained for up to thirty (30) days. Such information is maintained in Company's own systems and is not shared with advertising, analytics, or referral partners. Company does not use third-party analytics, advertising, or remarketing cookies.

II. Controls. Users may manage or disable cookies through their browser settings, although doing so may affect certain website or application functionality. Company does not currently use cookies for third-party advertising or cross-site behavioral tracking.

III. Browser and Opt-Out Signals. Company will recognize browser-based opt-out preference signals or other universal opt-out mechanisms to the extent required by applicable law and technically supported by Company’s systems. Other browser “Do Not Track” signals may not be recognized because there is no uniform industry standard governing such signals.

Article 8 — Contact; Changes

I. Privacy contact. Questions, privacy requests, or complaints regarding this Privacy Policy or Company’s privacy practices may be submitted to:

Utility Switch LLC, Attn: Legal Notices, 7901 4th St N, Ste 300, St. Petersburg, FL 33702; info@theutilityswitch.com.

II. Changes. Company may update this Privacy Policy from time to time to reflect changes in its Services, information practices, technology, legal requirements, or business operations. The updated Privacy Policy will be posted with a revised Effective Date, and Company will provide any additional notice or obtain any consent required by applicable law.

III. Effective date. Effective Date: October 16, 2026.