Privacy Policy

Last Updated on August 1st, 2025

## Privacy Policy

Bright Start Solar LLC

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You respond to our advertisements and tells You about Your privacy rights and how the law protects You. We use Your Personal Data to contact and support you, as well as to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

## Interpretation and Definitions

### Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

### Definitions

For the purposes of this Privacy Policy:

A2P 10DLC means Application-to-Person messaging using 10-digit long code numbers, a messaging standard that allows businesses to send SMS messages to customers using standard phone numbers registered with The Campaign Registry.

AI Assistant means automated software systems that may contact You via voice calls, text messages, or other electronic communications using artificial intelligence, prerecorded messages, voice synthesis technology, or voice cloning technology to provide information about our solar services, respond to inquiries, or deliver marketing communications.

Artificial Voice Communications means voice calls generated through artificial intelligence, voice synthesis, voice cloning, or prerecorded message technology, which are considered "artificial or prerecorded voice" under the Telephone Consumer Protection Act.

Automated System means any equipment or technology that has the capacity to store or produce telephone numbers to be called, using a random or sequential number generator, and to dial such numbers, or any automated system for the selection or dialing of telephone numbers or the playing of a recorded message when a connection is completed.

Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Bright Start Solar LLC.

Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.

Personal Data is any information that relates to an identified or identifiable individual.

Prerecorded Message means any artificial or prerecorded voice message, including ringless voicemail messages delivered directly to voicemail systems without ringing the recipient's phone.

Service refers to the advertisement, website, or application.

Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.

Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

## Collecting and Using Your Personal Data

### Types of Data Collected

#### Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

- First name and last name

- Email address

- Phone number and mobile number (including wireless numbers)

- Location details such as your address, city, state, and country

- Property ownership information and solar energy needs

- Communication preferences and consent records

- Call and message interaction history with our systems

- Records of consent provided for marketing communications

- Opt-out requests and Do Not Call preferences

- A2P 10DLC campaign registration information

- State-specific telemarketing compliance records

- Any other data such as personal preferences, solar energy requirements, or comments

### Use of Your Personal Data

The Company may use Personal Data for the following purposes:

- To provide and maintain our Service, including to monitor the usage of our Service and provide solar energy consultations

- To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user

- For the performance of a contract: the development, compliance and undertaking of the purchase contract for solar products, items or services You have purchased or of any other contract with Us through the Service

- To contact You: To contact You by email, telephone calls (including through AI Assistant using artificial, prerecorded, or AI-generated voices), SMS, text messages (including through A2P 10DLC registered campaigns and automated systems), prerecorded voicemail messages, ringless voicemail messages, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to solar installations, system monitoring, maintenance schedules, energy production reports, billing information, and security updates, when necessary or reasonable for their implementation

- Solar Services Communications: To contact You through our automated systems and A2P 10DLC registered messaging campaigns via voice calls using artificial intelligence, voice cloning, prerecorded voices, ringless voicemails, or automated dialing systems, text messages sent through A2P 10DLC registered campaigns, or other electronic communications for customer service, solar consultation scheduling, installation updates, system monitoring alerts, maintenance reminders, energy production reports, and marketing communications about solar energy products, financing options, and related services

- To provide You with news, special offers and general information about solar products, services, financing options, rebates, tax incentives, and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information

- To manage Your requests: To attend and manage Your requests to Us regarding solar consultations, installations, and services

- For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred

- For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, solar products, services, marketing and your experience

## Federal and State TCPA Consent and Communication Preferences

### Federal TCPA Consent Requirements

By providing your phone number and using our Service, you provide prior express written consent under the Telephone Consumer Protection Act (47 U.S.C. § 227) to receive voice calls and text messages from our automated systems. This consent includes:

- Voice calls using artificial intelligence, voice cloning, prerecorded messages, or ringless voicemails to your residential or wireless telephone number

- Text messages sent through A2P 10DLC registered campaigns and automatic telephone dialing systems

- Communications for customer service, solar consultation scheduling, and marketing purposes related to solar energy products, installations, financing options, and related services

- Contact at the phone number(s) you provide, including mobile and wireless numbers

- Communications that may include AI-generated content as disclosed at the beginning of each call

### One-to-One Consent Compliance

Your consent authorizes only Bright Start Solar LLC to deliver advertisements and telemarketing messages using artificial intelligence, automatic telephone dialing systems, or artificial/prerecorded voices to the telephone number you have provided. This consent covers communications that are logically and topically associated with solar energy products, services, installations, financing, and related offerings.

### State-Specific Compliance Requirements

#### For Florida Residents

Pursuant to the Florida Telephone Solicitation Act, your consent includes:

- Prior express written consent for automated systems for selection or dialing of telephone numbers

- Limitation of no more than 3 calls/texts per 24-hour period on the same subject matter

- Calls restricted to 8:00 AM to 9:00 PM Eastern Time

#### For Maryland Residents

Pursuant to Maryland's Stop the Spam Calls Act of 2023:

- Prior express written consent for automated systems for selection or dialing of telephone numbers

- Limitation of no more than 3 calls/texts per 24-hour period on the same subject matter

- Calls restricted to 8:00 AM to 8:00 PM Eastern Time

#### For Texas Residents

Pursuant to the Texas Telephone Solicitation Act and amendments effective September 1, 2025:

- Prior express written consent for telephone solicitations including text messages, graphic messages, and digital transmissions

- Calls restricted to 9:00 AM to 9:00 PM Monday-Saturday, 12:00 PM to 9:00 PM Sunday Central Time

#### For California Residents

California residents have additional privacy rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

- Right to know what personal information is collected and how it is used

- Right to delete personal information subject to certain exceptions

- Right to opt-out of the sale or sharing of personal information

- Right to limit the use of sensitive personal information

### A2P 10DLC Compliance

Our text messaging campaigns are registered with The Campaign Registry (TCR) and comply with A2P 10DLC requirements:

- Brand registration with verified solar business information

- Campaign registration with approved solar industry use cases and message samples

- Carrier compliance with trust scores and throughput limits

- Message content includes business identification and opt-out instructions

### Marketing Communications

You consent to receive marketing communications about solar energy products, installations, financing options, rebates, tax incentives, and related offerings through our automated systems, A2P 10DLC registered campaigns, and traditional communication methods.

### Required Disclosures

Clear and Conspicuous Disclosure: Your consent to receive artificial, prerecorded, and AI-generated calls includes consent to receive AI-generated calls and content related to solar energy services.

Real-Time AI Disclosure: When we use AI-generated voice technology, we will clearly disclose at the beginning of each call that the call is using AI-generated technology.

Call Time Restrictions: Marketing calls will only be made during permitted hours in your local time zone as required by applicable federal and state laws.

Frequency Limits: We will not exceed call/text frequency limits imposed by applicable state laws (typically 3 per 24-hour period on the same subject matter).

### Enhanced Opt-Out Rights (Effective April 11, 2025)

You may revoke consent or opt out of communications at any time by any reasonable means, including:

- Replying "STOP," "QUIT," "REVOKE," "OPT OUT," "CANCEL," "UNSUBSCRIBE," or "END" to any text message

- Saying "remove me from your list," "do not call," "stop," "revoke," or similar language during any voice call

- Calling our customer service line

- Emailing us at [email protected]

- Any other reasonable method of expressing your desire to stop receiving communications

### Processing Opt-Out Requests

Universal Application: An opt-out request made through any communication channel (voice, text, email) will apply to all future communications across every platform and campaign, whether marketing-related or informational.

Processing Timeline: We will process your opt-out request within 10 business days of receipt and cease all communications during this processing period.

Confirmation: We may send a one-time confirmation message to verify your opt-out request.

## Sharing Your Personal Information

We may share Your personal information in the following situations:

- With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You through traditional and automated communications, to provide artificial voice and automated messaging services, to maintain A2P 10DLC campaign compliance, and to provide solar installation, financing, and maintenance services

- For business transfers: We may share or transfer Your personal 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

- With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us

- With business partners: We may share Your information with Our solar industry business partners, financing partners, and installation contractors to offer You certain products, services or promotions, provided such sharing complies with TCPA and state telemarketing consent requirements

- With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside

- With Your consent: We may disclose Your personal information for any other purpose with Your consent

## Federal and State Compliance and Legal Requirements

### Do Not Call Registry Compliance

We maintain compliance with the National Do Not Call Registry and applicable state Do Not Call lists and will not contact numbers registered unless we have your prior express written consent or an established business relationship.

### State Do Not Call Lists

We comply with state-specific Do Not Call lists in: Colorado, Florida, Indiana, Louisiana, Massachusetts, Missouri, Oklahoma, Pennsylvania, Tennessee, Texas, and Wyoming.

### Record Keeping

We maintain records of all consent obtained, opt-out requests processed, and communications sent in compliance with federal TCPA requirements and applicable state laws for minimum required retention periods.

### Campaign Registration

Our A2P 10DLC campaigns are registered with The Campaign Registry and approved by major wireless carriers for compliant business messaging in the solar industry.

## Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (including federal TCPA and state telemarketing record-keeping requirements), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes and compliance monitoring.

## Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

## Disclosure of Your Personal Data

### Law Enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

### Other Legal Requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

- Comply with a legal obligation

- Protect and defend the rights or property of the Company

- Prevent or investigate possible wrongdoing in connection with the Service

- Protect the personal safety of Users of the Service or the public

- Protect against legal liability

## Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

## Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

## Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

## Contact Us

If you have any questions about this Privacy Policy, You can contact us via email at [email protected]

This Privacy Policy was last updated on August 1st, 2025

## Legal Notice

This Privacy Policy incorporates compliance with current Federal Communications Commission regulations under 47 CFR § 64.1200, the Telephone Consumer Protection Act as interpreted by federal courts, A2P 10DLC requirements administered by The Campaign Registry, and applicable state telemarketing laws including but not limited to Florida's Telephone Solicitation Act, Maryland's Stop the Spam Calls Act of 2023, Oklahoma's Telephone Solicitation Act, Washington state telemarketing laws, Texas Business & Commerce Code Chapter 302, New York General Business Law § 399-z, and California Consumer Privacy Act requirements. This policy addresses AI-generated voice communications as clarified by the FCC's February 8, 2024 Declaratory Ruling and incorporates the January 24, 2025 Eleventh Circuit decision in Insurance Marketing Coalition v. FCC regarding one-to-one consent requirements and the April 11, 2025 effective date for enhanced opt-out requirements under 47 CFR § 64.1200(a)(10).