SouthStar Energy Services LLC ("SouthStar", "we", "us" or "our") respects your privacy and is committed to complying with this privacy policy ("Privacy Policy"), which describes what information we collect about you, including how we collect it, how we use it, with whom we may share it and what choices you have regarding our use of your information. This Privacy Policy applies to information collected on our websites, which include, but are not limited to, southstarenergy.com, gng.com, onlyfng.com, grandrapidsenergy.com, marylandenergy.com, illenergysolutions.com, illenergy.com, onlyong.com, pennsylvaniaenergy.com and virginiaretailenergy.com (each, individually, a "Website" and, collectively, the "Websites"), any mobile applications associated with these Websites, including without limitation Google Contacts (the "Mobile Applications"), all interactive features such as Refer-A-Friend and other referral features, applications, widgets, blogs, social networks and social network "tabs", and other online or wireless offerings that post a link to this Privacy Policy, whether accessed via computer, mobile device or other technology or any associated content, material, or functionality contained on the Websites or Mobile Applications (collectively, the "Services" and, together with the Website and the Mobile Applications, the "System"). SouthStar operates as a natural gas marketer under the names "SouthStar Energy Services", "Georgia Natural Gas", "Ohio Natural Gas", "Maryland Energy", "Florida Natural Gas", "Grand Rapids Energy", "Pennsylvania Energy", and "Virginia Retail Energy." For the purposes of this Privacy Policy, references to "SouthStar" shall include SouthStar Energy Services LLC and all of its members, affiliates, subsidiaries (Illinois Energy, USA, LLC and Illinois Energy Solutions, USA, LLC) , directors, officers, agents, and employees.

This Privacy Policy is incorporated into and is a part of the terms of use of the System located here (the "Terms of Use"). We encourage you to become familiar with the terms and conditions of both this Privacy Policy and the Terms of Use. By accessing and using the System, or any part thereof, you agree that you have read and understand this Privacy Policy, and that in exchange for access to the System, you accept and consent to the privacy practices (and any uses and disclosures of information about you) that are described in this Privacy Policy.

As described in detail below, we may collect certain identifying information from or about you in connection with your use of, or your submissions to, the System (collectively, the "Collected Information"). Collected Information may include identifying information provided to the System on your behalf by one of our call center employees when you call our call centers to make a payment or enroll in one of our products or services. Collected Information includes, without limitation, any information that may be used to identify an individual, including, but not limited to, a first and last name, a home, business, service or other physical address, geographic location, business name, a phone number, a Social Security number, an email address, tax identification number, employer name, employer information (i.e., company size, industry, number of employees), utility account number or other identifier, credit or debit card number (and related information such as expiration date), bank account information, and account number or other identifier used in connection with our marketing alliances (e.g., your Delta SkyMiles number pursuant to our alliance with Delta). SouthStar uses the information we collect to provide natural gas and other products and services to you; to provide required regulatory communications to you; to open, maintain, and close accounts; for payment processing; for marketing activities; for fulfillment; for provision of quotes and other pricing information; to improve the System's content, materials, and services; and to more effectively and efficiently respond to both current and future customer inquiries.

Some of our promotional offers have a referral feature that allows you to have the offer sent to a friend or contact with your comment. If you choose to use this feature, we may collect from you and use the email address of your friend(s) and contact(s) to facilitate the referral. For your convenience, we offer you the option of accessing online contact sources, including, but not limited to the Google Contacts API feature, which will allow you to import the email addresses of your contacts solely for the purpose of selecting recipients with whom you wish to share a promotional offer. Any information provided to us through the referral feature will not be shared with any third parties or stored for other uses.

By placing a small file known as a "cookie" on your computer (or other device), SouthStar's, and its third party service providers, servers passively gather information about all visitors use of the System for several reasons, including, but not limited to, the following: statistics collection and analysis, System optimization, analytics (as described below), market research, and maintenance of user login information. The information that we and our third party service providers track with cookies includes, but is not limited to, the type of browser (such as Google Chrome or Internet Explorer) and Internet-connected device being used to access the System, your Internet protocol ("IP") address, your home domain or Internet service provider, your referrer URL (which is the URL for the website that you were viewing prior to visiting the System), how you were directed to the System, which specific pages you access on the System, how long you view each page, the time and date you access our System and the total number of visitors to the System and any portions thereof. We use your IP address to determine the general physical location of your computer or device and understand from what geographic locations our System visitors come.

We, and/or our third party service providers, may place cookies or similar files on your computer for security purposes (such as authentication), to facilitate site navigation and to personalize your experience while visiting our Website. Cookies allow us and our third party service providers to collect technical and navigational information, such as browser type, time spent on our Website and pages visited (these types of cookies are typically referred to as "Session Cookies").

Our third party service providers use pixels which cause "cookies" or similar technology to be stored on your browsers when you visit the System. This is necessary for our third party service providers to provide retargeting services. The collection of this anonymous data allows us to better target our advertising to your interests. The data also helps us and our third party service providers improve our respective product and services.

Most popular Internet browser applications will allow you to configure the browser so as not to accept cookies. However, setting your browser to reject cookies may, in certain instances, prevent you from taking full advantage of the System (or some portion thereof) and its capabilities, or cause some features of the System to function improperly or more slowly.

The Websites (and certain other portions of the System) use Google Analytics (including the Universal Analytics feature), a web analysis service provided by Google, in order to better understand your use of our Websites (or other portions of the System) and how we can improve the Websites and the System. Google Analytics collects information such as how often users visit a Website, what pages they visit when they do so, and what other websites they used prior to coming to such Website. Google Analytics collects only the IP address assigned to you on the date you visit the Websites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with your personal information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit a Website, the cookie cannot be used by anyone but Google. Google's ability to use and share information collected by Google Analytics about your visits to the Websites or the System is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. Google utilizes the data collected to track and examine the use of the System, to prepare reports on its activities and share them with other Google services. Google may use the data collected on the System to contextualize and personalize the ads of its own advertising network. To more fully understand how Google may use the data it collects on the System, please review "How Google uses data when you use our partners sites or apps", (located here or any successor URL). If you would like additional information regarding the security and privacy practices of Google's Universal Analytics feature, please review the materials provided by Google here.

Some of the areas of the System may contain electronic images known as web beacons (sometimes known as clear gifs) that allow SouthStar, and its third party providers, to count and track users who have visited certain portions of the System. Web beacons collect only limited information, including a cookie number, time and date of a page view, and a description of the page on which the Web beacon resides. Web beacons do not collect any of your personal information.

We appreciate your questions and comments about this Privacy Policy, the System and the Services and welcome your email messages to ContactUs@southstarenergy.com. If you correspond with SouthStar through the System or via email, the Collected Information may include the content of, and metadata regarding, any correspondence you may have with us. We may share your messages with those within our organization who are most capable of addressing the issues contained in your message. We will keep a copy of your message until we have had an opportunity to address your concerns. We may archive your message for a certain period of time or discard it.

We may send you emails with promotional offers. If you would no longer like to receive emailed special offer information, sales notifications or other promotional messages from us, please click the link at the bottom of any promotional email you receive from us and follow the instructions. Your email address will be removed from our marketing list. Please allow us a reasonable period of time in order to satisfy your request, as some promotions may already be in process.

If you elected to subscribe to any online services provided via the System, including the ability to manage your gas services account online (if this service is available), you will be required to submit personal information (including some Collected Information) for the purpose of verifying your identity and your authority to manage the account. This Collected Information will be used exclusively by SouthStar, our agents, suppliers and third-party service providers for internal use and to respond to your service requests and as otherwise contemplated by this Privacy Policy.

In addition to the uses mentioned or described elsewhere in this Privacy Policy or in the Terms of Use, we, and our third party service providers may use the Collected Information to analyze and improve the content, features, Services, Websites, and Mobile Applications that we make available on the System, as well to conduct certain targeted marketing activities specific to users. We may send you information that you request from us, promotional materials regarding SouthStar's services, and any other communication for any other legitimate and lawful business purposes. Additionally, we may retain and use certain Collected Information to facilitate and otherwise address certain inquiries, requests, subscriptions, or business transactions and relationship with SouthStar, or respond to your questions or requests for information about or from SouthStar or trusted business partners. If you contact us for support or assistance, we may use information about you or your system for purposes such as verifying whether your system meets the minimum requirements needed to use the System and our various Services. Additionally, we may transfer your Collected Information to our affiliates or trusted business partners for the purpose of advertising certain services provided by such affiliates or trusted business partners. We may also use Collected Information as necessary to ensure compliance with any SouthStar policies and any applicable law. SouthStar may also exchange Collected Information with other companies and organizations for fraud protection, credit risk reduction, and collection activities. Furthermore, if you request to open an account or transfer your account to the utility, we may share your Collected Information with the utility.

As part of the Services provided through the System, we may provide customized price quotes for natural gas services by collecting certain Collected Information (including name, business name, service address, email, phone number current natural gas supplier, and utility account number or other identifier) that is voluntarily provided by our System users. In order to provide such quotes, we may share such Collected Information with certain affiliates, third party service providers and trusted business partners as well as your utility. In addition to our other rights to use the Collected Information specified in this Privacy Policy, by submitting a request for quote via the System as described above, you grant us the right to share this Collected Information with our affiliates, third party service providers, business partners and the utilities to the extent necessary to obtain an accurate price quote.

Additionally, we may buy additional data related to Collected Information from certain trusted business partners for the purpose of creating custom demographic profiles, or to otherwise improve such users' System experience or use of our products or services.

In connection with our alliances with certain real estate agents and agencies, we may ask such third parties to refer potential customers to us by providing your name, address, email address and the closing date of your real estate transaction.

Furthermore, we may use your phone number or other Collected Information to "scrub" the information from our advertising lists if such Collected Information is included in a "Do Not Call" list (or such other no-contact list), or as may otherwise be necessary to comply with any regulation, law, or order. Furthermore, we may, but are under no obligation to, use Collected Information as necessary to ensure that existing customers or users of our services or products do not receive advertising for such products or services.

SouthStar may use various analytics tools and technologies regarding how users interact with the various portions of the System that require storage of web session data. These tools and technologies are used to assist System users by using cookies and scripts (as described in the "Cookies and Usage Reports" section above) to collect and store information such as how users interact with the System, errors users encounter when using the System, device identifiers, how often users visit certain portions or components of the System, what pages they visit, and what other sites they used prior to using to the System. Stored web session data used by such analytics services or tools is used in accordance with this Privacy Policy.

In addition to the uses mentioned or described elsewhere in this Privacy Policy or in the Terms of Use, we may catalog and add Collected Information to our database. We may also share your information with any of our affiliates, trusted business partners and third party service providers for the purpose of providing the System, for any other purpose described in this Privacy Policy or the Terms of Use, or for any other lawful purposes.When you submit a payment using the System, we may use third party payment processors to collect and process the Collected Information that is necessary to process your payment on our behalf, such as credit card information and billing address.

We, may from time to time, utilize a number of trusted business and marketing partners in delivering the content, materials, and opportunities available on or through the System. For example, we may provide your Collected Information to an affiliate or third party provider to re-target certain advertising to you on different portions of the System, for market or user modeling, or use in direct advertising through the System or via direct mailing. To the extent necessary for purposes of communicating with you or fulfilling your requests for such content, materials, and opportunities, we may share Collected Information with our affiliates, third party service providers or business partners. We, or our respective trusted business parties and third party services providers may also produce reports on the System's traffic or usage patterns and share these reports with us, or our business partners and others, but the information contained in these reports is anonymous and does not allow identification of any specific individual. SouthStar also may release Collected Information in connection with joint marketing efforts and strategic alliances.

We do not sell, rent, or lease our user lists or the identity of individual users to third parties. However, SouthStar may use and disclose certain aggregated, anonymized information, such as System usage data, to our affiliates, third party service providers or trusted business partners. Such information may also be shared with other users or the general public for advertising, informational, or comparison purposes. However, such information shall not be personally identifiable to any user.

We may also disclose Collected Information if we become subject to a subpoena or court or regulatory order, or if we are otherwise legally required to disclose information. We may also use and disclose Collected Information to establish or exercise our legal rights, to enforce the Terms of Use, to assert and defend against legal claims, or if we believe such disclosure is necessary to investigate, prevent, or take other action regarding actual or suspected illegal or fraudulent activities or potential threats to the physical safety or well-being of any person. In an effort to protect the security of our critical infrastructure, any use of a Website or information relating to such use may be monitored and disclosed to federal authorities or agencies.

As SouthStar grows and develops its business, it is possible that its corporate structure or organization might change or that it might merge or otherwise combine with, or that it or portions of its business might be acquired by, another company. In any such transactions, customer information generally is, and should be expected to be, one of the transferred business assets.

On the System, you may wish to participate in online polls, surveys, contests, sweepstakes and other promotions that we may offer from time to time. Participation in these polls, surveys, contests, sweepstakes and promotions is completely voluntary; you have a choice about whether or not to disclose information required to enter. Information requested may include personal contact information such as your name, address, date of birth, phone number, mobile phone number, e-mail address, username, and/or similar information. In addition, as noted above, we may share this information with affiliates and other organizations or entities. Through these online polls, surveys and promotions, you may choose to participate in activities such as sharing information found on the System with others and sending email invitations. In connection with any online polls, surveys, contests, sweepstakes and other promotions that we may offer from time to time via the System, we use the information you provide to administer the polls, surveys, contests, sweepstakes and other promotions. Subject to applicable contractual or legal restrictions, we also may use the information to communicate with you, or the other people you select, about our services or our marketing partners may use such information to communicate with you about the online polls, surveys, contests, sweepstakes or other promotions or their products and services.

When submitting information, corresponding, making requests for information, and otherwise interacting with SouthStar and its representatives through or in connection with the System, you choose what information to supply or submit, whether you wish to receive further information, and how you may be contacted. Please take care to share only such information as is needed or that you believe is appropriate. Note, however, that if you don't provide certain requested information, it may prevent us from providing certain Services to you and could also prevent you from taking full advantage of the System (or some portion thereof) and its capabilities, or cause some features of the System to function improperly. Any promotional email we send to you will contain a link which will allow you to opt out of receiving any further correspondence. If you have created an online account, you may have the ability to change your correspondence preferences by logging into your account and selecting your preferences.

SouthStar takes commercially reasonable measures to secure and protect information transmitted via or stored on the System. Nevertheless, no security system is impenetrable. We cannot guarantee that information that users of the System may happen to transmit or otherwise supply will be totally secure. You agree to immediately notify us of any breach of System's security, this Privacy Policy, or the Terms of Use of which you become aware.

For your convenience, some hyperlinks may be posted on the System that link to other websites not under our control. We are not responsible for, and this Privacy Policy does not apply to, the privacy practices of those sites or of any companies that we do not own or control. We cannot be responsible for the privacy practices of any such websites or pages not under our control and we do not endorse any of these websites or pages, the services or products described or offered on such sites or pages, or any of the content contained on those sites or pages. We encourage you to seek out and read the privacy policy of each website that you visit. In addition, should you happen to initiate a transaction on a website that our System links to, even if you reached that site through the System, the information that you submit to complete that transaction becomes subject to the privacy practices of the operator of that linked website. You should read that website's privacy policies to understand how personal information that is collected about you is used and protected.

Any information, communications, or material of any type or nature that you submit to any of our pages contained on a social media platform or website by e-mail, posting, messaging, uploading, downloading, or otherwise (collectively, a "Submission") is done at your own risk and without any expectation of privacy. We cannot control the actions of other users of a social media platform and we are therefore not responsible for any Submissions contained on a social media platform or website. By visiting any of our pages that are contained on any social media platform or website, you are representing and warranting to us that you have reviewed the applicable privacy policy and terms of use of such website or social media platform and that you will abide by all such provisions contained therein.

The System (including all Websites, Mobile Applications, and Services included therein) is intended for a general audience and is not intended for use or view by children under 13 years of age, and we do not knowingly collect information about children or sell products to children. Consistent with the Children's Online Privacy Protection Act, we will not knowingly collect any information from children under the age of 13. If you are under the age of 13, you must ask your parent or guardian to assist you in using the System. Furthermore, we may restrict entries to any contests, sweepstakes or promotions to entrants who are at least 18 years of age.

If you are visiting the System, or any part thereof, from outside of the United States of America, please be aware that your information may be transferred to, stored or processed in the United States, where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country, but please be assured that we take steps to protect your privacy. By using any portion of the System, you understand and consent to the transfer of your information to our facilities in the United States and those third parties with whom we share it as described in this Privacy Policy.

We may change this Privacy Policy at any time and from time to time. The most recent version of the Privacy Policy is reflected by the version date located at the bottom of this Privacy Policy. All such updates and amendments are effective immediately upon notice thereof, which we may give by any means, including, but not limited to, by posting a revised version of this Privacy Policy or other notice on the Website and the Mobile Applications. You should view this Privacy Policy often to stay informed of changes that may affect you, as your continued use of the System signifies your continuing consent to be bound by this Privacy Policy. We expressly reserve the right to make any changes to this Privacy Policy at any time, without prior notice to you. The version of this Privacy Policy posted here on each respective date you visit the System shall be the Privacy Policy applicable to your access and use of the System on that date. Our electronically or otherwise properly stored copies of this Privacy Policy shall be deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this Privacy Policy which were in force on each respective date you visited the System. This Privacy Policy is not intended to and does not create any contractual or other legal right in or on behalf of any party other than SouthStar.

If you have any questions or suggestions about the System, SouthStar (or any of our affiliates), our services, or our privacy practices, please contact us at ContactUs@southstarenergy.com.

BY ACCESSING OR USING THE SYSTEM, OR ANY PORTION THEREOF, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND CONSENT TO THE PRIVACY POLICY, AND TO THE USES AND DISCLOSURES OF COLLECTED INFORMATION ABOUT YOU, THAT ARE DESCRIBED IN THIS PRIVACY POLICY AND YOU AGREE TO BE BOUND BY THE TERMS OF USE REFERENCED ABOVE.
This Privacy Policy was last updated on August 5th, 2019.