Privacy Policy

Last Updated: June 11, 2026

Effective Date: June 11, 2026

1. Introduction

IMPAQ Holdings, LLC, a Florida limited liability company, doing business as Netwatt Systems ("Netwatt Systems," "we," "us," or "our") operates the website at netwattsystems.com and the Netwatt Energy Portal at start.netwattsystems.com (collectively, the "Services"). This Privacy Policy describes how we collect, use, share, and protect information when you visit our website or use our Services.

By using our Services, you agree to the practices described in this Privacy Policy. If you do not agree, please do not use our Services.

Our primary contact for privacy matters is:

Jeff Frahm

IMPAQ Holdings, LLC d/b/a Netwatt Systems

Jacksonville, Florida

Email: jfrahm@netwattsystems.com

Phone: (417) 844-4472

2. Information We Collect

2.1 Information You Provide Directly

When you create an account or submit an energy assessment request, we collect:

• Account information: Your name, business or company name, email address, and password
• Contact information: Phone number (optional)
• Property information: Business or facility address(es), property nicknames or identifiers, and any details you provide about your facility (square footage, equipment, usage patterns, etc.)
• Utility account information: Utility provider name, account numbers, and meter information that you provide or that we obtain through your authorized third-party data retrieval
• Utility bill data: Past utility bills you upload to our Services, or that we retrieve on your behalf through licensed third-party data partners with your authorization
• Payment information: If you use our paid Automatic Bill Retrieval service, payment processing is handled by our payment processor (Wix Payments). We do not store full credit card numbers. We receive only confirmation of payment, transaction ID, and the billing email address.

2.2 Information Collected Automatically

When you use our Services, we automatically collect:

• Device and usage information: IP address, browser type, operating system, device identifiers, pages visited, time spent on pages, and referring website
• Cookies and similar technologies: We use cookies to maintain your login session, remember your preferences, and analyze how our Services are used. See Section 7 for more about cookies.

2.3 Information From Third Parties

If you choose Automatic Bill Retrieval, we receive your utility data from our third-party data partner, UtilityAPI (or other authorized data providers). UtilityAPI accesses your utility account on your behalf only after you authorize them through their secure consent flow. We receive the resulting bill and usage data.

3. How We Use Your Information

We use the information we collect to:

• Provide our Services, including creating and managing your account, processing your energy assessment request, and generating your personalized energy savings proposal
• Communicate with you about your account, your request status, your proposal, follow-up questions, and service updates
• Process payments for the Automatic Bill Retrieval service through our payment processor
• Coordinate utility data retrieval with our licensed third-party data partners (such as UtilityAPI) when you choose that option
• Improve our Services, including analyzing usage patterns, troubleshooting issues, and developing new features
• Comply with legal obligations, including tax, accounting, and regulatory requirements
• Protect our Services against fraud, abuse, and unauthorized access

We do not use your information for advertising, marketing to third parties, or any purpose unrelated to providing the Services you requested.

4. How We Share Your Information

We do not sell your personal information. We do not share your data with third parties for their marketing purposes.

We share information only as described below:

4.1 Service Providers

We share information with trusted service providers who help us operate our Services, including:

• Base44 — our application hosting platform
• UtilityAPI — our licensed utility data retrieval partner (only if you choose Automatic Bill Retrieval)
• Wix Payments — our payment processor (only for paid services)
• Email service providers — for sending account and service-related emails
• Cloud storage providers — for storing your uploaded files and submitted data

Each service provider is contractually required to handle your information confidentially and only for the purposes we authorize.

4.2 Legal Requirements

We may disclose information when required by law, subpoena, court order, or other valid legal process, or to protect the rights, property, or safety of Netwatt Systems, our customers, or others.

4.3 Business Transfers

If Netwatt Systems is involved in a merger, acquisition, financing, or sale of assets, your information may be transferred as part of that transaction. We will notify you before your information becomes subject to a different privacy policy.

5. Data Retention

We retain your information for as long as necessary to provide our Services and fulfill the purposes described in this Privacy Policy, including:

• Account information: Retained while your account is active. If you close your account, we will delete or anonymize your information within 90 days, except where we are required to retain it for legal, tax, or accounting purposes.
• Utility bill data and energy assessment submissions: Retained for up to 7 years for legitimate business purposes (proposal records, customer service, repeat assessments) unless you request earlier deletion.
• Payment records: Retained for 7 years to comply with tax and accounting requirements.

You may request deletion of your information at any time by contacting jfrahm@netwattsystems.com.

6. Your Rights and Choices

You have the following rights regarding your personal information:

• Access: Request a copy of the information we hold about you
• Correction: Request that we correct inaccurate or incomplete information
• Deletion: Request deletion of your information (subject to legal retention requirements)
• Withdrawal of consent: Withdraw any consent you previously gave us
• Opt out of communications: Unsubscribe from non-essential emails using the link in any email we send

To exercise any of these rights, contact us at jfrahm@netwattsystems.com. We will respond within 30 days.

6.1 California Residents

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including the right to know what categories of personal information we collect, the right to delete, and the right to non-discrimination for exercising your privacy rights. We do not sell personal information.

6.2 European Residents

If you are in the European Economic Area, United Kingdom, or Switzerland, you have rights under the General Data Protection Regulation (GDPR), including rights to access, rectification, erasure, restriction, portability, and objection. Our legal basis for processing your data is the performance of our contract with you and your consent.

7. Cookies and Tracking

We use cookies and similar technologies to:

• Keep you logged in during your session
• Remember your preferences
• Understand how visitors use our Services
• Improve our Services

You can control cookies through your browser settings. Note that disabling cookies may affect the functionality of our Services.

We do not use third-party advertising cookies or tracking pixels.

8. Data Security

We implement reasonable administrative, technical, and physical safeguards to protect your information, including:

• HTTPS encryption for all data transmitted to and from our Services
• Encrypted storage of sensitive information
• Access controls limiting employee access to your data
• Regular security reviews of our service providers

However, no method of internet transmission or storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security. If we become aware of a security breach affecting your information, we will notify you as required by applicable law.

9. Children's Privacy

Our Services are designed for businesses and are not intended for use by individuals under 18. We do not knowingly collect personal information from anyone under 18. If you believe a minor has provided us with personal information, please contact us and we will delete it.

10. International Data Transfers

Our Services are operated from the United States. If you access our Services from outside the United States, your information will be transferred to, stored, and processed in the United States. By using our Services, you consent to this transfer.

11. Third-Party Links

Our Services may contain links to third-party websites (such as your utility's website or UtilityAPI's consent page). We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing them with information.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you by email (if you have an account) and update the "Last Updated" date at the top of this policy. Your continued use of our Services after a change indicates your acceptance of the updated policy.

13. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our handling of your information, contact:

Jeff Frahm

IMPAQ Holdings, LLC d/b/a Netwatt Systems

Jacksonville, Florida

Email: jfrahm@netwattsystems.com

Phone: (417) 844-4472

IMPAQ Holdings, LLC is a Florida limited liability company doing business as Netwatt Systems.