Privacy Statement

PRIVACY STATEMENT

Thank you for using Enron Corporation’s online and mobile resources and for viewing this privacy statement (the “Privacy Statement” or “Statement”). Our Privacy Statement, contained in the pages that follow, serves to give notice about the types of personal information we collect, how we use it, and who we share it with and why. We delve into those matters in a fair amount of detail in the pages that follow. We encourage you to read this Privacy Statement carefully. 

This Privacy Statement was amended as of December 2, 2024 and is effective as of that date. The English language version of this Privacy Statement is the controlling version regardless of any translation you may attempt. 

Please note that use of our online and mobile resources is also governed by our Terms of Use and Conditions of Sale (“Terms”). By accessing, using, or placing an order through our online and mobile resources you agree to these Terms. We encourage you to read the Terms carefully.

NAVIGATING THROUGH THIS STATEMENT

You can use the links on this page to navigate to areas of this Statement that apply specifically to you, or which may otherwise be of interest.

SOME IMPORTANT VOCABULARY

Although not itself a contract, this Privacy Statement is an important document that explains how we address some of our legal obligations, and your related legal rights, involving personal information. We’ll use this section to let you know about some words that have special meanings whenever you see them in this Statement. When we reference “this Statement”, “this Privacy Statement” and “our Statement”, we mean the Privacy Statement you are reading now. Wherever we say “Enron”, “Company”, “we”, “us”, or “our”, we mean Enron Corporation. We use the words “you” and “your” to mean you, the reader, and other visitors to our online and mobile resources who are, in all cases, over the age of 18. This age requirement is discussed in more detail later in this Statement here. 

When we talk about our “online and mobile resources”, we mean all websites, applications, portals or other features we operate to allow you to interact with us and our systems, as well as any mobile apps we’ve created and distributed to let you interact with the content we provide. An “affinity action” is when you “follow” us, “like” us or take a similar or analogous action on our external social media presence. 

Finally, and perhaps most importantly, when we refer to “personal information”, we mean any information, data or data element, whether in electronic or other form, that, alone or in combination with other elements, can be used to distinguish, trace, or discover your identity. Certain data privacy laws include specific elements or defined terms for what they consider to be personal information (sometimes also referred to as “personal data”). Where such data privacy laws apply, then the term “personal data” includes the specific elements and defined terms required by such laws. 

WHEN AND TO WHOM DOES THIS PRIVACY STATEMENT APPLY? 

Our online and mobile resources collect personal information from: (1) visitors to, and users of, our online and mobile resources; and (2) those who may interact with our ads and content displayed on third party sites. This Statement applies to our processing and sharing of personal information collected from the data subjects listed in the previous sentence. If we have legal obligations to other categories of data subjects, such as our employees, supply chain partners or vendors, we provide them with separate legally required notices in confidential contracts, policies, and other similar documents. 

HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

We collect and otherwise obtain your personal information in the following ways: (1) when you choose to give it to us by voluntary submission; (2) through automatic collection by technical means when you visit or use our online and mobile resources; and (3) when it is provided to us by external sources such as marketing companies, advertising companies, social media companies and/or companies that provide services on our behalf who, in each case, may have previously and separately collected elements of your personal information without our involvement and then shared it with us to us as part of a service for which we engaged that source.

Voluntary Submissions. Here are some of the ways you voluntarily give us your personal information:

• Creating Accounts – If we make an account creation feature available you will provide us your email address and other identifiers.
• Making Purchases – If you choose to make a purchase through our online and mobile resources, we will collect your name, email, phone number, residential address, and other information you provide to fulfil the order.
• Signing up for Newsletters – Similar to account creation, we collect some voluntarily submitted information if you sign up to receive a newsletter or other informational or marketing material we publish.
• Registering for Events – When you register for events or programs we may host, you will be submitting certain identifiers. If the event requires a fee, we may also ask you to submit credit card or other financial information. 
• Sending Emails and Texts – If you choose to send us an email from our “contact us” link or a similar link, you will be giving us your email address and any other personal information that may be in your message or attached to it. The same is true if you send us a text message. 
• Using Community Features – Some of our online and mobile resources may offer social media-like community features letting users post messages and comments, and/or upload image or other files and materials. If you choose to make use of these features, the information you post, including your screen name and any other personal information, will be in the public domain and may not covered/protected by this Statement.  

If you prefer that we not receive the above-described personal information, please don’t submit it. This means you shouldn’t participate in the applicable activities on or use the applicable features available from our online and mobile resources. Your use of our online and mobile resources is strictly your choice. By not participating, you may limit your ability to take full advantage of the online and mobile resources, but most of the content in our online and mobile resources will still be available to you and we never discriminate on the basis of how much information you provide.

Automatic Collection.  When you visit or use our online and mobile resources, information about your internet/electronic activity is automatically collected through your browser via tracking technologies, such as “cookies.” As just about everyone knows by now, cookies are small text files downloaded onto your computer or mobile device. Cookies allow us to collect your IP address and recognize your computer or mobile device and store some information about your preferences for using our online and mobile resources or past actions. Please see our Cookie Notice for more information.

If you access our online and mobile resources from a phone or other mobile device, the mobile services provider may transmit to us certain information such as uniquely identifiable mobile device information. That, in turn, allows us to collect mobile phone numbers and associate them with the mobile device identification information. 

External Sources. We may work with companies who provide us with data, including personal information, so that we can tailor our services to audiences who have the most interest. We also may work with digital advertising and marketing companies to provide you with ads that meet your interests and that enhance your experience with us. These ads may be displayed on websites or device applications operated by third parties. These third parties collect information with their own cookies, pixels, and related tracking technology and then provide that information to us. We are not responsible for their data collection practices.  

Further, we maintain a presence on one or more external social media platforms such as Twitter, Facebook, YouTube and LinkedIn. We may allow the community features of our online and mobile resources to connect with, or be viewable from, that external social media presence. Similarly, our online and mobile resources may contain links to other websites or apps controlled by third parties. We are not responsible for either the content on, or the privacy practices of, social media platforms, or any third-party sites or apps to which we link. Those apps, sites and platforms are not controlled by us and therefore have their own privacy policies and terms of use. To be clear: neither this Statement nor our Terms apply to our social media presence or any third-party sites or apps to which we may link. That means even if you take an affinity action on our specific social media presence, and identifiers about you are automatically collected and given to us as a result, that collection and transfer is governed by the privacy policies and other terms of the applicable social media platform and are not our responsibility. 

If you have questions about how those apps, sites, and platforms collect and use personal information, you should carefully read their privacy policies and contact them using the information they provide. In addition, certain coalitions of advertisers allow consumers to opt out of receiving interest-based advertising from members of those coalitions. You can visit the Digital Advertising Alliance and Network Advertising Initiative  to opt out of receiving interest-based advertising from members of these coalitions. You will need to exercise these opt outs on each browser on each device for which you wish to opt out of interest-based advertising.

WHAT TYPES OF PERSONAL INFORMATION DO WE COLLECT?

The categories of personal information we have collected from visitors and users of our online and mobile resources in the previous 12 months, and may collect from you, are as follows:

• General Identifiers such as a real name, alias, online identifier, Internet Protocol address, date of birth, postal address, email address, account name, or other similar identifiers.
• Commercial Information including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Internet Activity Data or other similar electronic network activity information, such as browsing history, search history, and information regarding a consumer's interaction with our online and mobile services or an advertisement regardless of device type used, be it a personal computer, cell phone or other mobile device.
• Audio/Visual Data such as profile or account photos, access to a phone camera to input transaction details, or videos or other electronic recordings, such as recordings of customer service phone calls. 
• Analytics and Inference Data drawn using the above-described personal information to create a profile reflecting our customers’ interests and preferences or to otherwise improve our goods and services.

Sensitive Personal Information. We do not collect “sensitive personal information” or “sensitive data” as these terms are defined by applicable law.

Deidentified Information. We may collect deidentified data and inferences derived from the categories of personal information described in this Statement. This data does not identify you in any way. We will not reidentify, or attempt to reidentify, any deidentified information that we collect as described in this Statement.

HOW DO WE USE THE PERSONAL INFORMATION WE COLLECT? 

Use for Legitimate Business Purposes.  We use the personal information we collect only in the manner and through the means allowed by applicable law. That means we determine whether we have a lawful basis or legitimate business purpose to use your personal information before doing so. Generally speaking, we collect personal data from you where we have your consent to do so, where we need the personal data to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. Specifically, we use personal information for the following business purposes:

• Transaction Processing – such as processing, completing, and maintaining records of transactions.
• Performance of Contracts – such as fulfilling our duties and exercising our rights under contracts we may have with you or our vendors and supply chain partners. 
• Promotions – such as providing personalized promotions and special offers.
• General Marketing – such as providing users with information about our brand, products, and events.
• Tailored Marketing – providing users with marketing tailored to their interests.
• Account Servicing – facilitating and servicing your account.
• Physical Security – providing security at our physical locations and for internal or external investigations.
• Technical Security – monitoring our networks and detecting security incidents.
• Customer Service – responding to consumer inquiries, including requests for information, online support and phone calls.
• User Experience – such as internal research and analytics to improve user experience on our online and mobile resources.
• Knowing Our Customer – understanding the demographics and interests of our online and mobile resource visitors.
• Debugging – debugging, identifying, and repairing errors that impair existing intended functionality of our online and mobile resources.
• Detecting and Preventing Unlawful Acts – protecting against malicious or illegal activity and prosecuting those responsible.
• Verification – verifying accounts and responding to consumer requests.

Retention of Your Personal Information.  We store and retain your personal information in accordance with applicable law and as long as necessary to carry out the purposes described above and in accordance with our internal data retention procedures. The criteria used to determine the retention periods include: (1) how long the personal information is needed in connection with the purposes for which we use it; (2) the type of personal information collected; and (3) whether we are subject to a legal, contractual or similar obligation to retain the personal information (e.g., mandatory data retention laws, government orders to preserve personal information relevant to an investigation, or personal information that must be retained for the purposes of litigation or disputes). 

 

WHEN/WITH WHOM DO WE SHARE PERSONAL INFORMATION?

We may share the categories of personal information described in this Privacy Statement with third parties. We do not control these third parties or how they use information. Within the last 12 months we have shared such personal information with the following categories of third parties for the business purposes described below:

• Corporate Affiliates – We may share personal information with our corporate affiliates or corporate parents who will use such information in the same way as we can under this Statement.  
• Operations Support Vendors – We may share your personal information to vendors that help us to operate and increase the efficiency of our business and our online and mobile resources.
• Customer Support Vendors – We may share your personal information with vendors that provide customer support services, such as chatbot, phone, or email support. 
• Promotional or Fulfillment Vendors – In order to carry out promotions we make available to you and/or deliver our goods and services, we are required to share personal information with vendors who specialize in those activities. 
• Software and Technology Vendors – Our various service providers may have access to or be provided with some of your personal information in connection with the tasks they perform on our behalf such as maintaining portions of our networks or the software applications that run on them. 
• Transaction Support Vendors / Payment Processors – We share personal information with those of our vendors and business partners that process payments on our behalf and send you confirmations and administrative messages.
• Marketing and Advertising Providers – We may share your personal information to third parties, including social media networks, who support online advertising, data co-operatives, mobile advertising, data analytics, social media engagement, and other advertising networks that support our marketing efforts.
• Security and Fraud Prevention Providers – We also may disclose personal information to third party security and fraud prevention providers when we have reason to believe that someone is causing injury to or interference with our rights or property or harming or potentially harming other persons or property.
• Law Enforcement or Government Agencies – We may disclose personal information to government agencies and authorities, and to other third parties when compelled to do so by such government authorities, or at our discretion, or otherwise as required or permitted by law, including responding to court orders and subpoenas. 
• Successors for Business Sale/Purchase – If we, or any of our affiliates, sell or transfer all or substantially all of our assets, equity interests or securities, or are acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, divestiture, consolidation, or liquidation, personal information may be one of the transferred assets.

In some jurisdictions, our transfer of information to third-party providers for marketing and advertising purposes could be defined as “selling” personal information or “sharing” personal information for “cross-context behavioral advertising.” In the past 12-months, we have transferred the following categories of information to third parties for marketing and advertising purposes: (1) persistent identifiers, such as unique device identifiers, email addresses, account information, IP addresses, information related to your browser and operating system, or any information that you provided through the Site; and (2) user activity data, such data generated through your activities on our online and mobile resources. 

Disclosing your Personal Information. We may disclose the categories of personal information described in this Statement for the business and commercial purposes described in this Privacy Policy to the categories of third parties as described in this Privacy Policy, which may include: (1) our service providers and suppliers; (2) our business and marketing partners, including advertising networks; (3) data analytics providers; and (4) other parties in connection with business transfers and for legal, safety, fraud prevention, and enforcement reasons. We use and partner with different types of entities to assist with our daily operations and to manage our online and mobile resources.

DO NOT TRACK SIGNALS

Do Not Track (“DNT”) is a privacy preference that users can set to have their Internet browser automatically send a signal to our online and mobile resources to request that we do not track browsing activity across different sites. However, there is currently no universal standard for sending and receiving DNT signals. As such, we cannot promise that we respond to all DNT signals.

COOKIES AND OTHER TRACKING TECHNOLOGIES

We use cookies and other tracking technologies to provide, protect, and improve our online and mobile resources and to collect, use, and share your information as described in this Privacy Statement. Specifically, cookies help us by storing your preferences and settings, personalizing content, serving ads, enabling you to sign-in, gathering information such as browser type and operating system, combating fraud, and analyzing use and performance of our online and mobile resources. Please see our Cookie Notice for more information. 

YOUR PRIVACY RIGHTS 

Where applicable based on privacy laws in your jurisdiction, you may have certain rights you can request that we fulfill. These rights may include:

• The Right to Know. You have the right to request that we disclose the information that we have collected about you and identify the purposes for which the information was used, whether and to whom it was shared, and what sources it was obtained from. 
• The Right to Delete. You have the right to request that we delete information that we maintain about you, subject to certain exceptions.
• The Right to Correct. You have the right to correct any information that we store about you.
• The Right to Opt-Out of Your Personal Information Being Sold or Shared. You may opt-out of us sharing or selling your information by contacting us at compliance@enron.com or by visiting us at our Do Not Sell or Share My Personal Information page.
• Right to Opt-Out of Targeted Advertising. You have the right to request that we opt you out of targeted advertising.
• Right Not to Receive Discriminatory Treatment. Exercising your rights under this Privacy Statement will not result in any discrimination by us. We will treat you the same as any other user.
• Right to Complain. You have the right to complain to a data protection authority about our collection and use of your information. For more information, please contact your local data protection authority. 
• Right to Withdraw Consent from Processing. If we have collected and processed your information based on your consent, then you can withdraw your consent at any time. 
• Right to Data Portability. You have the right to request that we provide you with a copy of your information on file with us. 
• Right to Appeal. If you make a request to exercise any of the applicable data access rights and we are unable to comply with your request, you may request to appeal our decision. To appeal any data privacy request decision, please contact us by emailing us at compliance@enron.com with the subject line “Data Access Request Appeal.” If after you complete the appeal process with us, you are still not satisfied with our response, you may contact your state’s Attorney General to file a complaint. 

 

HOW TO EXERCISE YOUR PRIVACY RIGHTS 

In order to exercise any of the rights detailed in this Privacy Statement, please contact us at compliance@enron.com or visit our data subject request page. We may require additional information from you to help us verify your identity and state or country of residence, and to otherwise process your request. The verification steps may vary depending on the sensitivity of the information and whether you have an account with us. If we are unable to verify your identity, we may deny your requests to know or delete. You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and must verify your identity directly. 

CHILDREN’S PRIVACY

Federal law imposes special restrictions and obligations on commercial website operators who direct their operations toward and collect and use information from children under the age of 13. We take those age-related requirements seriously, and, consistent with them, do not intend for our online and mobile resources to be used by children under the age of 18, and certainly not by anyone under the age of 13. Moreover, we do not knowingly collect personal information from minors under the age of 18. If we become aware that anyone under the age of 18 has submitted personal information to us via our online and mobile resources, we will delete that information and not use it for any purpose whatsoever. We encourage parents and legal guardians to talk with their children about the potential risks of providing personal information over the Internet.

SUBMITTING INFORMATION FROM OUTSIDE THE UNITED STATES 

We control and operate the online and mobile resources from within the United States of America (the “U.S.”). Information collected through the online and mobile resources may be stored and processed in the United States or any other country in which Enron or its affiliates or service providers maintain facilities. To the extent applicable, we rely on the latest revision of the standard contractual clauses promulgated by the European Commission for transfers of personal data from the European Economic Area (EEA), United Kingdom (UK), or Switzerland to our online and mobile resources within the U.S. 

PROMOTIONAL MESSAGES

By signing up to any of our promotional lists, you are giving your express permission to Enron and its agents or vendors the right to contact you with targeted advertising materials by email, text message (“SMS”), telephone or cellphone, including the use of automated, predictive, programmable, or similar automatic dialers or dialing software, or any other means of communication we may utilize to provide promotional offers. Your consent is not a condition of purchase. To the extent applicable, you expressly acknowledge that you are solely responsible for all charges billed by your mobile service provider. We may share your data, including your SMS opt-in or consent status, with third parties that help us provide our messaging services, including but not limited to platform providers, phone companies, and any other vendors who assist us in the delivery of promotional messages.

If you no longer wish to receive promotional communications by email, please follow the unsubscribe link located at the end of an email message. If you no longer wish to receive promotional text messages, reply STOP, END, CANCEL, UNSUBSCRIBE, or QUIT to any mobile message from Enron. When we receive your request, we will take reasonable steps to remove you from our distribution lists, but it may take time to do so. You may still receive materials for a period of time after you unsubscribe. Unsubscribing or changing affinity actions or other submissions or requests made on our external social media presence, will likely require that you do so directly on that applicable social media platform as we do not control their procedures. 

CHANGES TO THIS PRIVACY STATEMENT

We reserve the right to change or update this Statement from time to time. If we determine that such changes materially affect your privacy rights, we will provide additional notice to you. Please check our online and mobile resources periodically for such changes since all information collected is subject to the Statement in place at the time of collection. We will indicate the effective/amendment date at the beginning of this Statement. 

CONTACTING US

If you have questions about our Privacy Statement or privacy practices, please contact us at:

Email: compliance@enron.com