For the purposes of this Privacy Policy, “Personal Information” is information that relates to, describes, is capable of being associated with, or could reasonably be linked (directly or indirectly) with you or your household, and may include Technical Data. “Technical Data” refers to device, Internet and network activity information that we, our business partners, and our service providers collect, including information about how you interact with our Websites and Services. “Energy Usage Data” means any electric and gas usage data collected through the use of SJI Services, or that SJI collects from its service providers and other third parties, when associated with any information that can reasonably be used to identify an individual, family, household, residence, or non-residential customer. We may combine Technical Data and Energy Usage Data with other Personal Information we have about you.

If we combine or connect non-Personal Information with Personal Information so that it directly or indirectly identifies you as an individual, we treat the combined information as Personal Information. This may happen if, for example, you are signed into your account when using our Websites.

We collect Personal Information you provide to us, Technical Data, and Energy Usage Data, and we may also receive information from other parties, as described in this Privacy Policy.

Information You Provide Directly To Us

You may provide your Personal Information in a variety of ways, including when you sign up for an SJI account or Services, participate in one of our community events, sign up to receive communications from us, contact us, or otherwise use a Service. Categories of Personal Information you may provide under these circumstances include:

• Contact Information, such as your name, postal or service address, email address, telephone number, username, or other similar identifiers, such as social media handles.
• Customer Records, including information related to records of Services that you purchased, obtained, considered, or may be interested in, as well as information related to your transactions with us, such as your payment history.
• Demographic Information, which may include protected classification characteristics under state and federal law, such as your signatures, military or veteran status, physical disabilities, gender, age, or other background information, such as your ethnicity if you inquire about programs applicable to minorities. Unless it is necessary for us to collect this information about you to provide you with services or information you requested, we only collect this information as statistical, or aggregated information, which does not directly or indirectly reveal your identity or directly relate to you.
• Government Verification and Account Information, such as Social Security number, tax identification number, driver’s license number, state or government-issued identification card number, account number, bank account number, credit card or debit card number. We collect this information only to provide our Services. Please do not provide this information in response to an email or phone call unless you have initiated the request.
• Payment Information, such as name, billing address, bank account information, and payment card details (including payment card number, expiration date and security code), some of which is collected and stored by our third-party payment processor on our behalf (see the Information Provided From Other Parties section below).
• General Geolocation Data when you are using the Websites.
• Audio, Electronic, or Visual Information, such as your electronic messages, questions or comments when you contact us through the Websites, as well as audio or video recording when you call us or when you come to our customer service center locations or join recorded conference calls, but please note we may not be able to associate such recordings with you.
• User Contributions when you disclose information about yourself on SJI’s social media pages. Further, if you choose to submit content on our social media pages, the content will be considered “public” and not be subject to the privacy protections provided by this Privacy Policy. User Contributions are submitted at your own risk. Although you may have certain privacy settings for such contributions, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other social media users with whom you choose to share your User Contributions.

Sensitive Personal Information. Some of the above information may be considered “Sensitive Personal Information” under the laws of certain jurisdictions, and we may use information that you provide to us to provide and support our Services, comply with our legal obligations, or defend against a legal claim. We do not collect or use Sensitive Personal Information other than for operational, business or compliance purposes.

Technical Data

As you interact with our Websites, we may automatically collect technical data about your device, browsing actions, and patterns. This data may not reveal your specific identity by 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 Websites, and other technical information. This information is primarily needed to maintain the security and operation of our Websites, and for our internal analytics and reporting purposes. However, some of these technologies are utilized for marketing purposes. If you are signed into an account, your search information or information associated with your visit to our Websites may reveal or be associated with your identity. We encourage you to consider this as you navigate and use our Websites.

Technical Data we collect may include:

• 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 Websites 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 on the Websites (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), or device event information (such as system activity, error reports or “crash dumps,” and hardware settings).
• Device Data. We may automatically collect device data such as information about your computer, phone, tablet, or other device you use to access the Websites. 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 and version, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Details about your Website Interactions, including through use of what is now commonly known as “session replay” or “fingerprinting” technologies, which may include data relating to including the full Uniform Resource Locators (URLs), clickstream information to, through, and from our Websites (including date and time), services viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods used to browse away from the page.
• Cookies and Other Tracking Technologies. such as first party and third-party products and services to gather traffic statistics using cookies, pixels, or web beacons. A cookie is a small piece of information stored on your device that helps our websites and multiple servers recognize you. We, our Service Providers, and other third parties may also use other tracking technologies such as pixels, or transparent GIF files, for website management and user tracking.

Some of the technologies we use are strictly necessary for the functionality of our websites. Others improve the functionality of our websites but are not strictly necessary. Some cookies help improve the performance of our websites (such as by gathering analytic data), while others help provide targeted advertising services to you (like ads that you may be interested in). Examples of cookies and other tracking technologies we use include:

• Session Cookies. We use Session Cookies to operate our Websites. Session cookies are temporary and are automatically deleted once you close your internet browser.
• Preference Cookies. We use Preference Cookies to remember your preferences and various settings. Preference cookies are first party cookies that remain on your computer or device until you delete them, or they are otherwise removed upon expiration.
• Third Party Cookies. We may permit third-party business partners, advertisers, and other companies to use cookies or other similar technologies on our websites. These companies may collect your information, track your behavior on our websites, and gather information about your use of our websites, and other online services over time and across different services. Additionally, some companies may use information collected to deliver targeted ads on behalf of us or other companies, including on other apps, websites, or online services. We are not responsible for the functioning of cookies and other technologies used and placed by third parties on your device. We do not always control third parties’ collection or use of your information to serve interest-based advertising. These third parties may provide you with ways to choose not to have your information collected or used in this way. Please refer to the Your Privacy Rights section below.
• Pixel Tags, Web Beacons, and Transparent GIFs. Pixel tags and web beacons are tiny graphic images placed on Website pages or in our emails that allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, the pixel tags and web beacons generate a notice of that action. These tools allow us to measure response to our communications and improve our Websites.
• Other Technologies. We collect many different types of information from other technologies to improve the quality of our Websites and the Services we provide. For example, we may collect usage data and other information about the device you use to access our websites, your operating system and/or mobile device type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. We may record the IP address of the device you use to connect to the internet.

We may use cookies and other tracking technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Click the Cookie Preferences link for more information on use of tracking technologies for behavioral or targeted advertising and how to limit or opt-out of such use. For information about how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking, see the Interest-based Advertising and Your Privacy Rights sections below.

Energy Usage Data

Energy Usage Data we collect may include the types of energy appliances in use at your residence.

Information Provided From Other Parties

We may receive Personal Information about you from third parties that handle Personal Information on our behalf at our instruction under certain contractual terms, including our affiliates; service providers, including, chat function, data analytics and internet providers; vendors, including technical, billing and accounting vendors; financial partners; and other third-party sources, including commercially available sources. Advertising and social media partners may also give us information about you, and we may combine Personal Information we receive from outside sources with other Personal Information that we have about you for the purposes described in this Privacy Policy.

Utility Billing and Payment Services. When you access the Elizabethtown Gas Company or South Jersey Gas Company Websites to view your account information you will be directed to the website of our My Account site which is hosted by Meridian. Payment collected on the site is processed by our payment collection provider, known as Bill2Pay.

• PLEASE NOTE that when you click the link that says, “Manage Your Account” to pay your billing statement or access certain account information, you will be directed to the KeepTrac My Account website.
• PLEASE NOTE that when you send us payment via check or money order for your gas bill via the billing mailer addressed to: Elizabethtown Gas Company, PO Box 6031, Bellmawr, NJ, 08099-6091 or South Jersey Gas Company, P.O. Box 6091, Bellmawr, NJ 08099-6091, as appropriate, those checks are gathered securely and then shredded after the payments are applied.

The Personal Information that we collect depends on the context of your interactions with us, including the use of the Websites and Services. 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.

We generally use your Personal Information to offer you Services and products, communicate with you, deliver advertising and marketing, fulfill our legal obligations, or to conduct other business operations, such as using information to improve and personalize your experiences. Examples of how we may use the Personal Information we collect include to:

• Present our Websites and provide you with the information, Services, and support that you request from us.
• To process and fulfill your product orders, process payment for the products you purchase, and ship products to you.
• Meet our obligations and enforce our rights arising from any contracts with you, including for billing or collections.
• To bill you for our Services.
• Fulfill the purposes for which you provided the information or that were described to you when it was collected, including to determine whether you are eligible for certain programs, rebates and financing options, and to facilitate your participation in our energy-efficient program marketplaces.
• Notify you about changes to our Services or products.
• Ensure that we present our Websites’ content in the most effective manner for you and for your computer.
• Administer our Websites and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical, and survey purposes.
• Improve our Websites and Services, marketing, or customer relationships and experiences.
• Enable your participation in our Websites’ interactive and live chat functions, social media, or other similar features.
• Protect our Websites, employees, or operations.
• Measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you;
• Make suggestions and recommendations to you and other users of our Websites about Services that may interest you or them.
• Comply with our legal requirements.
• In other ways for which we provide specific notice and obtain your consent if required by applicable law.

We may also use Personal Information to contact you about our Services and certain products that may be of interest to you. If you do not want us to use your information in this way, please check the relevant box located on the order or registration form or adjust your user preferences in your account profile. For more information, see the Your Privacy Rights section below.

We may use non-Personal Information for any business purpose. We may combine information we obtain about you for the purposes described in this Privacy Policy or any supplemental notice.

How We Use Energy Usage Data

As permitted or required by law, we use Energy Usage Data that we collect to provide and inform you about our Services, including but not limited to:

• To prepare billing statements and track payment history.
• To allow you to access your Energy Usage Data, when available.
• To communicate with you about your plans and pricing.
• To communicate with you about energy saving and environmental matters; and
• To improve our Services.

We may also combine information about your energy usage with other customers’ usage data such that it is anonymous, non-identifiable information. For example, we may combine anonymized Energy Usage Data to evaluate energy usage in a specific neighborhood or region. We use anonymized Energy Usage Data to provide and improve the Services, including to analyze our customers’ energy usage and rates and anticipate energy usage patterns.

We may disclose your Personal Information to our affiliates and other business partners, service providers, marketing partners and state regulatory agencies. We may also disclose your Personal Information with other parties to enforce our rights, in connection with a business transfer or merger, for safety or security purposes, or other reasons for which we may notify you from time to time. Our Websites employ cookies and tracking technologies to help us improve your experience and understand your interests and to allow SJI and our advertising partners and social media platforms to display relevant advertisements on SJI and others’ websites, apps, or devices you use.

Subject to restrictions and conditions set out in applicable laws, we may share the above categories of Personal Information with:

• Any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, and our affiliates.
• To our product purchase fulfillment, shipment, transportation and/or delivery providers.
• Business partners, suppliers, service providers, sub-contractors, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization).
• Advertisers and advertising networks that require the information to select and serve relevant ads to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in a specific location). We may make use of the Personal Information we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.
• Credit reference vendors when obtaining your credit score before entering into a contract with you, including when you apply for a new energy efficiency loan.
• State agencies, and other utilities, to the extent required by law.

We may also externally disclose your Personal Information:

• In the event that we sell or buy any business or assets, in which case we may disclose your Personal Information to the prospective seller or buyer of such business or assets.
• To a buyer or other successor in the event of 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, where one of the transferred assets is the Personal Information we hold.
• To comply with any court order, law, or legal process, including responding to a government or regulatory request.
• To enforce or apply our terms of use or terms and conditions of supply and other agreements.
• To protect the rights, property, or safety of our business, our employees, our customers, or others. This includes exchanging information with energy regulatory agencies or other critical infrastructure companies and organizations for the purposes of cybersecurity, fraud protection, and credit risk reduction.

We may disclose aggregated and other non-Personal Information that does not identify any individual, without restriction.

How We Disclose Energy Usage Data

We may disclose your Energy Usage Data to our service providers who act on our behalf under specific contractual terms and other third parties as permitted or required by law or as described in this Privacy Policy. We do not disclose Energy Usage Data without your prior consent, except as necessary for us to:

• Provide our Services.
• Operate and maintain our energy systems and infrastructure.
• Comply with a valid warrant, subpoena, or court order.
• Comply with a valid NJ Board of Public Utilities request or request from other state or federal governmental agencies with legal authority to obtain the data from SJI.
• Enable service providers and other third parties to provide utility and associated services on our behalf; and
• Provide assistance in emergent circumstances.

Directing SJI to Share Energy Usage Data. You may authorize other individuals or entities to receive your Energy Usage Data. We encourage you to read the privacy policy and related terms of any third parties with which you share your Energy Usage Data to understand how they may use and disclose your information.

Some content or applications, including advertisements, on our Websites are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Websites. They may associate the information collected with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites or other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

Please be aware of this any time you interact with social media content through our Websites or connect your social media account to our Websites through social login.

We do not control how these third-party tracking technologies operate or how they may use the collected information. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see the Your Privacy Rights section below.

These third parties may provide you with ways to choose not to have your information collected or used in this way. Please also refer to the Information We Collect and How We Collect It section of this Privacy Policy and the specifics about third-party sources that we describe, including the links to the privacy policies of these third parties and the choices these third parties provide regarding opting out of information sharing. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website or members of the Digital Advertising Alliance (“DAA”) on the DAA’s website. For information about these opt-out programs and to opt-out of the use of website browsing data for interest-based advertising by companies that participate in these programs, click the following: NAI Opt Out or DAA Opt Out.

We strive to provide you with choices regarding certain Personal Information uses, particularly around marketing and advertising. Here, you can learn about the various decisions you may make about your Personal Information use and disclosure.

Right to Know: You have the right to confirm whether we process your Personal Information.

Right to Access / Portability: You may ask to obtain the specific pieces of Personal Information we have collected about you in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the Personal Information to another entity without hindrance.

Right to Correction: You may request that we correct any inaccurate Personal Information we maintain about you.

Right to Deletion: You may request that we delete any Personal Information about you we that we collected from you unless retention of the Personal Information is required by law.

Communications

Text Messages. You can stop receiving SMS messages by replying STOP to any of our messages.

Mailings. You can stop receiving certain postal mail by submitting a request to contactus@sjindustries.com with “Privacy Policy” in the subject line. Note that some postal mail is required to provide you with mandatory notifications about your services.

Promotional Offers, Questionnaires and Account Emails. You have a choice as to whether you want to receive advertisements, questionnaires, newsletters or company information from us. If you do not want us to use your contact information for advertising purposes, you can opt-out by following the instructions in the advertising communication, by logging into your My Account Portal on the Websites and adjusting your account profile’s user preferences, or by sending us an email with your request to contactus@sjindustries.com with “Privacy Policy” in the subject line. You may also opt-out of further marketing communications by replying to any promotional email we have sent you or following the “Unsubscribe” opt-out link on that message. Terminating advertising emails will not automatically stop you from receiving certain other account emails. If you are a customer and wish to opt-out of all electronic communications, you must log into your account on the Websites and adjust your account profile’s user preferences.

Online Surveys. From time to time, you may be asked to participate in online surveys on the Website. Online surveys are used so that we can gather information to better serve you. Based on the information you provide to us; we may inform you of accounts and services from the SJI. As always, if you have asked us not to contact you for promotional purposes, your request will be honored and these surveys will be optional.

Tracking, Targeted Advertising, and Third-Party Advertisements

If you do not want us to share your Personal Information for targeting advertising purposes, you can opt-out by contacting our Customer Service Department at 609-561-9000 or by emailing contactus@sjindustries.com with “Privacy Policy” in the subject line. You may also be able to set your browser to decline all or some browser cookies, or to alert you when Websites set or access cookies. If you disable or decline cookies, please note that some parts of the Websites may become inaccessible or not function properly.

Do Not Track Signals

Our Websites are not designed to respond to “do not track” signals received from browsers.

Account Settings and Contributions

Online Account Holders – Access and Deletion. You can review and change your Personal Information by logging into the Websites and visiting your account profile page. You may also send us an email at contactus@sjindustries.com with “Privacy Policy” in the subject line to request access to, correct, or delete any Personal Information that you have provided to us. We cannot delete your Personal Information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

User Contributions. If you delete your User Contributions from our social media pages, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Website users.

Accessing Your Energy Usage Data. We provide you with information about your Energy Usage Data via billing statements and your online account. Customer Energy Usage Data is updated monthly and includes billing period and associated fee information. Our website also provides rate, pricing, and billing information.

To help protect your privacy and provide you with quality service, we rely on you to provide us with complete and accurate information. To update or correct your information, please use the My Account Portal on the Websites to access your customer account, or reach out to us with the information found in the Contact Us section at the end of this Privacy Policy.

Data Security. The security of your Personal Information is very important to us. We use physical, technical, and administrative safeguards designed to protect your Personal Information a from loss, misuse, and unauthorized access, use, alteration, or disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Websites, you are responsible for choosing a strong password and keeping this password confidential. We ask you not to share your password with anyone. We urge you to take care when providing information in public areas of the Websites, which any Website visitor can view.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Websites. Any transmission of Personal Information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Websites.

Data Retention. Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes for which we collected it, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve disputes. To determine the appropriate retention period for Personal Information, we consider applicable legal requirements, the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information, and whether we can achieve those purposes through other means.

To appeal our decision on your data subject requests, you may contact our compliance office by emailing us at contactus@sjindustries.com. with “Privacy Policy Appeal” in the subject line. Please enclose a copy of or otherwise specifically reference our decision on your data subject request, so that we may adequately address your appeal. We will respond to your appeal in accordance with applicable law.

We are based in the United States. We may process, store, and transfer the Personal Information we collect, in and to a country outside your own, with different privacy laws that may or may not be as comprehensive as your own.

If you are located outside United States and choose to provide information to us, please note that the information, including Personal Information, will be transmitted to and stored in United States. By submitting your Personal Information or engaging with our Websites and Services, you consent to this transmission, storing, or processing.

We will take all steps reasonably necessary to ensure that your information is stored and transmitted securely and in accordance with this Privacy Policy.

Please note that this Privacy Policy does not apply to the practices of third parties on their own websites, including our service providers, marketing partners, or other third parties. When you access a third party’s website through links on our websites, information collected from you by others on those third-party websites, is governed by those entities’ privacy policies. SJI is not responsible for and does not control the security or privacy of your information when you visit those sites. We encourage you to read the privacy policy of every website you visit.

We request that children under the age of 16 not use the Websites or submit any Personal Information to the Websites. We do not direct the Websites to children under the age of 16 and we do not knowingly collect, use, store, or disclose the Personal Information of children under the age of 16. If we learn we have unintentionally collected or received Personal Information from or about a child without appropriate consent, we will take reasonable steps delete it. If you believe we unintentionally collected any information from or about a child, please contact us through the Contact Us section below.

We will post any changes we may make to our Privacy Policy on this page and indicate on the Websites home page that we updated this Privacy Policy. If the changes materially alter how we use or treat your Personal Information we will notify you by email to the primary email address specified in your account and/or through a notice on the Websites’ home pages. Please check back frequently to see any updates or changes to our Privacy Policy.

Please address questions, comments, and requests regarding this Privacy Policy and our privacy practices by calling us at 609-561-9000 or by emailing us at contactus@sjindustries.com. with “Privacy Policy” in the subject line.