Privacy Policy

Last modified: 31 August 2025

Introduction

Ithaca Clean Energy, Ltd. ("Company," "we," "us," or "our") respects your privacy and is committed to protecting it through our compliance with this policy. This policy describes:

The types of information we may collect or that you may provide when you download, install, register with, access, or use the Waterfront mobile application and/or website (collectively, the "Platform").
Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies only to information we collect through Platform and in email, text, and other electronic communications sent through or connected with the Platform.

This policy DOES NOT apply to information that:

We collect through any other Company apps or websites.
You provide to or is collected by any third party (see Third-Party Information Collection).

Our other websites and apps, and these other third parties may have their own privacy policies, which we encourage you to read before providing information on or through them. Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it.

If you do not agree with our policies and practices, do not download, register with, or use thE Platform. By downloading, registering with, or using thE Platform, you agree to this privacy policy.

This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Platform after we revise this policy means you accept those changes, so please check the policy periodically for updates.

Children Under the Age of 16

The Platform is not intended for children under 16 years of age, and we do not knowingly collect personal information from children under 16. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at privacy.inquiries@waterfrontapp.com.

Information We Collect and How We Collect It

We collect information from and about users of the Platform:

Directly from you when you provide it to us.
Automatically when you use the Platform.

Information You Provide to Us

When you download, register with, or use the Platform, we may ask you provide information:

By which you may be personally identified, such as name, postal address, email address, telephone number, or any other identifier by which you may be contacted online or offline ("personal information").
That is about you but individually does not identify you, such as your gender, date of birth, and your primary and secondary language.

This information includes:

Information that you provide by filling in forms in the Platform.
Information provided at the time of registering to use the Platform, subscribing to our service, and requesting further or additional services. We may also ask you for information when you report a problem with the Platform.
Records and copies of your correspondence (including email addresses and phone numbers), if you contact us.
Your responses to surveys that we might ask you to complete for research purposes.
Details of transactions you carry out through the Platform and of the fulfillment of your orders. You may be required to provide financial information before subscribing to a service on or through the Platform.

Automatic Information Collection and Tracking

When you download, access, and use the Platform, it may use technology to automatically collect:

Usage Details. When you access and use the Platform, we may automatically collect certain details of your access to and use of the Platform, including traffic data, aggregate location data, logs, and other communication data and the resources that you access and use on or through the Platform.
Device Information. We may collect information about your mobile device and internet connection, including the device's unique device identifier, IP address, operating system, browser type, mobile network information, and the device's telephone number.
Stored Information and Files. The Platform also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips.
Location Information. This Platform collects aggregate real-time information about the location of mobile devices but such information does not identify you or your device personally. If you do not want us to collect this information do not download the Platform or delete it from your device. For more information, see Your Choices About Our Collection, Use, and Disclosure of Your Information. Note, however, that opting out of the Platform's collection of location information will disable its location-based features.

We do not use these technologies to collect information about your activities over time and across third-party websites, apps, or other online services (behavioral tracking).

Information Collection and Tracking Technologies

The technologies we use for automatic information collection may include:

Web Beacons. Pages of the Platform and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).

Third-Party Information Collection

When you use the Platform, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:

Analytics companies.
Your mobile device manufacturer.
Your mobile service provider.
Our service providers hosting the Platform.

These third parties may use tracking technologies to collect information about you when you use the Platform. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties' tracking technologies or how they may be used. 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 Your Choices About Our Collection, Use, and Disclosure of Your Information.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information, to:

Provide you with the Platform and its services, and any other information, products or services that you request from us.
Fulfill any other purpose for which you provide it.
Give you notices about your account, including expiration and renewal notices.
Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
Notify you when Platform updates are available, and of changes to any products or services we offer or provide though it.

The usage information we collect helps us to improve our Platform and to deliver a better and more personalized experience by enabling us to:

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Platform according to your individual interests.
Speed up your searches.
Recognize you when you use the Platform.

We use location information we collect to:

Provide location specific information and updates to you when you are using the Platform.
Access certain features of the Platform that require location information.
Using aggregated location information to inform and improve analysis and decision-making features of the Platform.

We may also use your information to contact you about our own services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile. For more information, see Your Choices About Our Collection, Use, and Disclosure of Your Information.

We do not currently use the information we collect to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction. In addition, we may disclose personal information that we collect or you provide:

To our subsidiaries and affiliates.
To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Ithaca Clean Energy, Ltd.'s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Ithaca Clean Energy, Ltd. about our Platform users is among the assets transferred.
To fulfill the purpose for which you provide it. For example, if you give us an email address to use the "contact us" feature of our Platform, we will transmit the contents of that email and your email address to the recipients.
For any other purpose disclosed by us when you provide the information.
With your consent.
To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce our rights arising from any contracts entered into between you and us, including the Platform EULA, Terms of Service, and for billing and collection.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Ithaca Clean Energy, Ltd., our customers or others.
This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Your Choices About Our Collection, Use, and Disclosure of Your Information

We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information.

Tracking Technologies. You can choose whether to allow the Platform to collect information through other tracking technologies by configuring the applicable settings on your mobile device. If you block the use of other tracking technologies, some parts of the Platform may then be inaccessible or not function properly.
Location Information. You can choose whether or not to allow the Platform to collect and use real-time information about your device's location through the device's privacy settings. If you block the use of location information, some parts of the Platform may become inaccessible or not function properly.
Promotion by the Company. If you do not want us to use your email address to promote our own services, you can opt-out by emailing us at privacy.inquiries@waterfrontapp.com. You can also always opt-out by logging into the Platform and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes.

We do not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

Accessing and Correcting Your Personal Information

You can review and change your personal information by logging into the Platform and visiting your account profile page. You may also send us an email at privacy.inquiries@waterfrontapp.com to request access to, correct, or delete any personal information that you have provided to us. 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.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, please review our California Consumer Privacy Addendum.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.

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 the Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we take commercially reasonable efforts to protect your personal information, we cannot guarantee the security of your personal information transmitted through the Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

Important Notices to Non-U.S. Residents

The Platform and its servers are operated in the United States. If you are located outside of the United States, please be aware that your Information, including your personal information, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to use the Platform, you hereby irrevocably and unconditionally consent to such transfer, processing, and use in the United States and elsewhere.

App Stores; External Websites

Your app store (e.g., iTunes or Google Play) may collect certain information in connection with your use of the Platform, such as personal information, payment information, and other usage-based data. We have no control over the collection of such information by a third-party app store, and any such collection or use will be subject to that third party’s applicable privacy policies.

The Platform may contain links to third-party websites. We have no control over the privacy practices or the content of these websites. As such, we are not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-party privacy policy and terms of use when visiting any other websites.

Changes to Our Privacy Policy

We may update our privacy policy from time to time. If we make material changes to how we treat our users' personal information, we will post the new privacy policy on this page with a notice that the privacy policy has been updated and an in-Platform alert the first time you use the Platform after we make the change. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

Email: privacy.inquiries@waterfrontapp.com

Via our toll-free number: +1(212) 729-0807

California Consumer Privacy Addendum

This Privacy Addendum for California Residents supplements the information contained in Company's Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Addendum.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information") as further described in our Privacy Policy. We obtain the categories of personal information listed below as described in our Privacy Policy. In particular, we have collected the following categories of personal information from its consumers within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	NO
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	NO
G. Geolocation data.	Physical location or movements.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	YES
I. Professional or employment-related information.	Current or past job history or performance evaluations.	YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose as described in our Privacy Policy. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has not disclosed personal information for a business purpose.

Sales of Personal Information

In the preceding twelve (12) months, we have not sold personal information.

Your Rights Under the CCPA.

You have the right under the CCPA and certain other privacy and data protection laws, as applicable, to exercise free of charge, your:

Right to Know. You have the right to request information about: (a) the categories of personal information we have collected about you, (b) the categories of sources from which we collected the personal information, (c) the purposes for collecting the personal information, (d) the categories of third parties with whom we have shared your personal information, and (e) the purpose for which we shared your personal information. You may also request information about the specific pieces of personal information we have collected about you.
Right to Delete. You have the right to request that we delete the personal information that we have collected from you.
Right to Opt-Out. You have the right to opt-out of the sale of your personal information.

We will not discriminate against you, in any manner prohibited by applicable law, for exercising these rights.

We will endeavor to respond to your request within forty-five (45) days of receiving your request or notify you that we need additional time to process your information.

Deletion Request Rights

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug the Platform to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

How to Exercise Your Rights

If you would like to exercise any of your rights as described in this Addendum, please:

Call us, toll-free, at +1(212) 729-0807; or
Email us at privacy.inquiries@waterfrontapp.com.

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period. If you choose to contact directly by email, phone, or in writing, you will need to provide us with:

Enough information to identify you (e.g., your full name, address, and customer or matter reference number);
A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collect information or is someone authorized to act on such person’s behalf. Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.