Clay Electric Cooperative, Inc.

Digital Communications Privacy Policy and Messaging Terms

This Digital Communications Privacy Policy and Messaging Terms ("Policy") explains how Clay Electric Cooperative, Inc. ("Clay Electric," "we," "us," or "our") collects, uses, discloses, retains, and protects information when you use the Clay ECI mobile application, enroll in or receive email, SMS/MMS text, push, or other electronic notifications, or communicate with us through those channels.

1. Scope

This Policy applies to the Clay ECI mobile application (the "Application") and to email, SMS/MMS text messages, push notifications, and other digital communications that Clay Electric sends or receives. The Application and our communication services may be provided with Meridian Cooperative and other technology vendors acting on Clay Electric's behalf.

This Policy supplements any more specific privacy notice, agreement, or disclosure that applies to your cooperative membership, electric service, payment transaction, program participation, or use of a third-party service. If a more specific notice conflicts with this Policy, the more specific notice governs for that activity.

2. Information We Collect

Information You Provide

We collect information that you provide when you register for or use the Application, enroll in notifications, manage your communication preferences, make a payment, respond to a message, or contact us. Registration may be optional for some Application features, but account-specific and personalized features may require registration.

• Identity, contact, and account information. This may include your name, email address, mobile or other telephone number, mailing and service address, Clay Electric account number, username, password or other authentication information, and related registration details.
• Billing, payment, and transaction information. When you make or arrange a payment, you may provide card, bank account, e-check, billing, and transaction information. A payment processor may collect this information directly. Clay Electric may receive transaction records, payment status, or limited identifiers rather than complete card or bank details.
• Communication preferences and consent records. This includes the channels and categories you select, the mobile number or email address enrolled, the date and method of opt-in, and records of later preference changes or opt-out requests.
• Communications and support information. We collect the information you include in emails, text replies, forms, outage or service reports, support requests, surveys, and other communications with us.

Information Collected Automatically

When you use the Application or interact with a digital communication, the Application or our service providers may collect certain information automatically, including:

• Device and connection information. Device type, unique device or application identifier, Internet Protocol (IP) address, operating system, browser type, app version, network information, language, and similar technical details.
• Application and website activity. Dates and times of access, screens or features used, links selected, session information, cookies or similar technologies used within the Application or linked webpages, diagnostic data, crash reports, and error logs.
• Message delivery and interaction information. Whether a communication was sent, delivered, delayed, failed, bounced, opened, or selected; responses to messages; and HELP, STOP, unsubscribe, or other preference requests.

Location Information

Depending on the Application features you use, and only when your device settings permit, the Application may use GPS or similar technology to determine an approximate or precise location so it can display location-based maps or information relevant to your service. We do not share your current precise location with other users. We may provide location information to service providers only as necessary to operate the requested feature. You can disable location access in the Application or your device settings, but some location-based features may not function.

Information From Clay Electric Systems and Service Providers

We may combine information collected through digital channels with information in Clay Electric's member and service systems, such as service address, account status, billing and payment history, electric usage, outage or restoration status, service orders, program participation, and prior communication preferences. We may also receive delivery, security, and support information from vendors that operate the Application or communication systems for us.

3. How We Use Information

We use information collected under this Policy to:

• Provide and administer digital services. Create and authenticate accounts; provide Application features; display account, usage, billing, payment, outage, and service information; and process transactions or requests.
• Send communications you request or that relate to your account or service. These may include outage and restoration alerts, planned interruption notices, billing and payment reminders or confirmations, past-due or account notices, service and meter updates, safety or emergency information, identity or security messages, cooperative news, program information, event or meeting reminders, surveys, and other categories you select.
• Manage consent and preferences. Document how and when you enrolled, apply your channel and category choices, process STOP or unsubscribe requests, and maintain suppression records so we can honor opt-outs.
• Provide support and protect our systems. Respond to questions, troubleshoot errors, maintain service quality, detect or prevent fraud and misuse, secure accounts and systems, and investigate incidents.
• Improve operations. Analyze performance and use of the Application and communication services, develop or improve features, and evaluate message effectiveness. Where practical, we use aggregated or de-identified information for these purposes.
• Meet legal and operational obligations. Comply with applicable laws, regulations, court orders, cooperative record-retention requirements, audits, dispute resolution, and protection of Clay Electric, our members, and the public.

4. How We Disclose Information

We may disclose information in the following circumstances:

• Service providers and communication partners. We may provide information to vendors that host, operate, support, secure, or analyze the Application and our systems; process payments; send email, text, push, or other notifications; provide customer support; and supply telecommunications or network services. This includes mobile carriers and messaging providers that must process mobile information to deliver texts. These recipients may use the information only to perform services for Clay Electric or as otherwise permitted or required by law.
• Legal, safety, and compliance purposes. We may disclose information when we reasonably believe disclosure is required by law, legal process, regulation, audit, or governmental request, or is necessary to protect rights, property, safety, service reliability, system security, or the public.
• At your direction or with your consent. We may disclose information when you ask or authorize us to do so, including to complete a transaction or connect you with a service you request.
• Organizational transactions. If Clay Electric participates in a merger, consolidation, asset transfer, reorganization, or similar transaction, information may be disclosed as reasonably necessary for that transaction and remains subject to applicable privacy obligations.
• Aggregated or de-identified information. We may use or disclose information that does not reasonably identify an individual for operational, analytical, reporting, and planning purposes.

5. Digital Communications and Messaging Terms

SMS/MMS Text Messaging

Enrollment and consent: When you affirmatively enroll a mobile number in a Clay Electric text-notification program, you authorize Clay Electric to send recurring automated or non-automated SMS/MMS messages to that number about the message categories described at enrollment or selected by you. Consent to optional text messages is not a condition of receiving electric service. Your consent applies only to Clay Electric's program and is not transferred to another company for its marketing or promotional use.

Message types: Depending on your selections and account relationship, messages may include outage and restoration updates; planned service interruptions; billing, payment, past-due, and account notices; service or meter updates; safety and emergency information; identity or security messages; cooperative news, programs, surveys, events, and meeting reminders; and other notifications identified when you enroll.

Message frequency and charges: Message frequency varies based on your selections, account activity, and events affecting electric service. You may receive recurring messages. Message and data rates may apply according to your mobile service plan. Clay Electric does not charge a separate fee for enrolling in the text-notification program.

Opting out: Reply STOP to any Clay Electric text message to unsubscribe from text messages sent through that program. We may send one final message confirming your opt-out. After that confirmation, we will not send further recurring text messages through the program unless you enroll again. Opting out of text messages does not opt you out of email, push notifications, postal mail, or other channels; manage those preferences separately.

Help: Reply HELP for assistance, email admin@ceci.coop, call 618-662-2171 or 1-800-582-9012, or write to the address in the Contact Us section below.

Delivery and carrier limitations: Text-message delivery is subject to your carrier and network availability and is not guaranteed. Wireless carriers are not liable for delayed or undelivered messages. Do not rely solely on a text message to report an outage, hazardous condition, or emergency. For outage reporting, call 1-800-582-9012. For an immediate threat to life or property, call 911.

Number changes and message security: Keep your mobile number current and notify us before transferring or discontinuing a number enrolled in the program. Text messages are not a secure channel. Do not send passwords, full payment-card or bank-account information, Social Security numbers, or other highly sensitive information by text.

Email Notifications

You can unsubscribe from optional or promotional email by using the unsubscribe link in an applicable email or by contacting us. Even after you unsubscribe from optional email, we may send non-promotional account, transaction, service, security, legal, or other communications permitted or required by law. Where available, you may update email categories and delivery preferences in the Application or account portal.

Application and Push Notifications

You may manage push-notification categories in the Application, when available, or disable push notifications in your device settings. You can stop future collection through the Application by uninstalling it using your device's standard process. Disabling notifications or uninstalling the Application does not close your Clay Electric account, delete information already retained, or change your preferences for email, text, postal mail, or other channels.

6. Your Choices and Requests

You may review or update certain account information and communication preferences through the Application or account portal, when those features are available, or by contacting us. You may also ask us to access, correct, or delete information you provided through the Application or communication services. We will respond within a reasonable time and as required by applicable law.

Some information cannot be deleted on request because it is needed to provide electric service, complete a transaction, maintain account or payment records, document consent or opt-out status, resolve disputes, protect security, or satisfy legal, regulatory, accounting, audit, or record-retention obligations. Deleting information needed for an Application feature may prevent that feature from functioning.

7. Data Retention

We retain information for as long as reasonably necessary for the purposes described in this Policy, including while you use the Application or receive communications, and afterward as needed for account administration, service operations, consent and preference records, security, disputes, audits, and legal or regulatory obligations. Retention periods vary by the type of information and the system in which it is maintained.

Automatically collected Application device and usage information may be retained for up to 24 months and then deleted, aggregated, or de-identified, unless a longer period is reasonably necessary for security, troubleshooting, legal compliance, or another purpose described above. Information in backups may remain until the backups are overwritten in the ordinary course.

8. Security

We use reasonable administrative, physical, and technical safeguards designed to protect information we process and maintain. We limit access to authorized employees, contractors, and service providers who need the information to perform their duties. No method of transmission, storage, or security can prevent every loss, misuse, or breach, and we cannot guarantee absolute security.

9. Children

The Application and Clay Electric's notification programs are not directed to children under 13, and we do not knowingly solicit personal information from or market to children under 13 through these services. If a parent or guardian believes a child has provided personal information without appropriate consent, please contact us. We will take reasonable steps to delete the information, subject to legal and operational retention requirements.

10. Third-Party Services and Links

The Application and our communications may link to or use services provided by payment processors, app stores, mobile carriers, websites, or other third parties. Their independent collection and use of information is governed by their own privacy notices and terms. This Policy governs Clay Electric's practices and information processed by vendors on our behalf; it does not replace the privacy notices of independent third parties.

11. Processing in the United States

Information covered by this Policy is processed and stored in the United States. If you use the Application or communication services from outside the United States, your information will be transferred to and processed in the United States under applicable United States privacy standards.

12. Changes to This Policy

We may update this Policy from time to time. We will post the updated Policy at a publicly accessible location on our website and revise the effective date. When appropriate, we may also provide notice through the Application, email, text message, or another reasonable channel. If applicable law requires consent to a material change, we will request that consent.

13. Contact Us

For privacy questions, communication preferences, or requests concerning information covered by this Policy, contact:

Clay Electric Cooperative, Inc.

Attn: Privacy / Digital Communications

PO Box 517, 7784 Old Hwy 50, Flora, IL 62839

Email: admin@ceci.coop

Phone: 618-662-2171 or 1-800-582-9012