Supplemental Privacy Statement

Last Updated: Sept 05, 2025

Stem, Inc. and its subsidiaries (Collectively known as “Stem”) respect your privacy and commit to protecting it through our compliance with the practices described in this privacy statement (this “Privacy Statement”).

Please read this privacy statement carefully.

Scope

This Privacy Statement describes our policy for collecting, using, maintaining, protecting, and disclosing (collectively, “processing”) your personal information when you use our services, including:

This Privacy Statement and our separately provided Privacy Notice only apply to personal information we collect about you.

What is Personal Information?

“Personal information” (sometimes called “personal data”) when used in the context of this Privacy Statement, means information that is reasonably capable of identifying a particular individual (including through their device) either alone or when combined with information from other sources.

What Information Do We Collect?

The personal information we collect about you depends on the nature and context of your interaction with Stem. It may also depend on various choices you make about how to use the services we offer, the functionality and features you choose or enable, your location, the devices you use to interact with Stem and our services, and applicable law.

Personal Information You Provide to Us

We collect the following categories personal information you provide to us:

Contact Information: Including, but not limited to, for example, first and last name, title, email address, phone number, physical address, job titles, and other contact information you provide.

Account and Other Identifiers: Including, but not limited to, for example, username, screen name, handle, account ID, assigned user ID, customer number, or similar identifier that can be used to identify and user or account.

Sensitive Personal Information: Some jurisdictions have defined certain categories of personal information as sensitive (“Sensitive Personal Information”). We collect the following categories of Sensitive Personal Information when you provide it to us or allow us to collect it based on your business interaction with us.

Payment Processing Information: Including, but not limited to, for example, the form of payment, payment card number and details, bank account number, payment service provider, and other payment information you provide.

Precise Location Information: A specific determination of your location using longitudinal and latitudinal coordinates determined by GPS where meters and other hardware provided by Stem is housed.

Personal Information We Derive Through Your Use of Our Services

We automatically collect certain information about your (and your device) interaction with our services using various data-gathering and tracking technologies, including cookies or tracking pixels and web beacons to monitor activity. Our website stores cookies for analytics and metrics, which are used to customize and improve your browsing experience. The information we collect using these technologies includes:

Website Log and Usage Data. Data related to our pages you viewed, the services and features you used or interacted with, your browser type and details about any links or communications with which you interacted.

Diagnostic Data. Such as crash logs, launch time, hang rate, energy use, and other information collected for measuring technical diagnostics.

For more information about the tracking technologies we use, please see our Cookie Notice.

Who Provides Us with Personal Information?

We collect personal information directly from you or based on your interaction with our website, service or product.

What Do We Do with Your Personal Information?

We may use your personal information for a variety of reasons. Depending on how you interact with our services, these include:

When we process personal data about you to comply with legal requirements or to perform our obligations under a contract with you or with our customer through which you use our offerings, failure to provide such data may prevent or delay our fulfillment of these obligations.

Does Stem Sell Personal Information?

“Selling” in this context means the delivery of your personal information to third parties in exchange for money. Stem does not sell your personal information to third parties.

When and With Whom Do We Share Your Personal Information?

We may share your personal information with the following:

Business Operations Providers: Including cloud computing service providers, internet service providers, data backup and security providers, functionality and infrastructure providers, and similar service providers.

Our Business Affiliates: With our affiliates, subsidiaries, joint venturers, or other companies that we control or that are under common control with us.

We may also gather aggregated data about individuals and disclose the results of such aggregated (but not personally identifiable) information to our partners, service providers, advertisers, and other third parties for marketing or promotional purposes.

STORAGE AND TRANSFER OF DATA

Stem ensures data in transit and at rest are always encrypted. To achieve this, we have put in place appropriate technical and organizational measures like firewalls and SSLs (Secure Sockets Layer) in line with NIST 800-53 framework in place to protect your data against unauthorized processing, accidental loss, destruction or damage.

How Long Do We Keep Your Personal Information?

We will retain your personal information only for so long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider 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; and the applicable legal requirements. In some circumstances, you may ask us to delete your data. Additionally, we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

How Do We Protect Your Personal Information?

We have implemented and maintain reasonable security procedures and practices, appropriate to the nature of the information, to protect your personal information from unauthorized access, destruction, use, modification, or disclosure. However, no security measure is perfect, so we cannot guarantee the security of your personal information.

Examples of our security measures include the following:

Because your data security is of utmost importance to our business, we employ industry best practices to ensure the protection of your data.

Do We Collect Information from Minors?

Our services are not intended for persons under 18 years of age. We do not knowingly collect or process the personal information of individuals under the age of 18. If we learn that we have collected personal information from a child under age 18, we will delete that information as quickly as possible. If you believe that a child under 18 may have provided us with their personal information, please contact us at client.support@stem.com.

A cookie is a text-only string of characters that is temporarily stored in your computer’s memory. Our cookies are time-sensitive and automatically expire. If the expiration of a cookie is set to be longer than the time you spend on a site, then this text-only string is saved in a cookie on your computer’s hard drive for future reference; otherwise, it disappears from your computer when your browser is closed.

How do Cookies function?

The cookies we use cannot retrieve information from your computer’s hard drive, cannot destroy files, and cannot send viruses to your computer. When a cookie is placed on your computer’s hard drive, it does not allow access to your personal information, but it may be used to identify your computer. Stem’s website uses cookies to track the pages on our website that a user visits, so that information can be customized to the visitor for each session on our website, and so that future visits may be enhanced. This is a quick and convenient method of keeping our website’s content fresh and relevant to the website visitor. Most web browsers give you the ability to prevent your browser from accepting new cookies, to have the browser notify you when you receive a new cookie and to disable cookies entirely.

You can still review our website if you set your browser to refuse all cookies, but you must enable cookies to register on our websites.

What Are Your Privacy Choices?

You can control the collection and use of personal information for some of our processing activities. This includes:

Adjusting Communication Preferences

Email: You may unsubscribe from promotional and other types of communications by following the “unsubscribe” instructions near the bottom of the email. You may also email us at client.support@stem.com. Please note, opting out of promotional emails will not stop you from receiving all emails from Stem. For example, we may still send you emails pertaining to your purchases, registrations, consumer surveys and similar transactions.

Blocking Cookies

Most web browsers automatically accept cookies by default, but you can alter how your browser responds to cookies by adjusting the settings. Information about managing cookies for popular web browsers can be found in the links below:

  • Safari (Desktop) and Safari Mobile (iOS). ( Task for hubspot guys)
  • Firefox
  • Chrome
  • Microsoft Edge
  • Brave

Additionally, you may use our cookie consent preference manager to customize your cookie preferences for our website.

Blocking Google Analytics

Many websites, including ours, employ Google Analytics. To opt out of Google Analytics data collection, follow these instructions from Google.

International Data Transfers

If you provide personal information through our website or in connection with other services or products we offer, you understand that we may process, store, and transfer your personal information in and to a foreign country, including the United States. The laws that apply to the use and protection of personal information in the United States, or other countries or jurisdictions in which we transfer or process personal information, may be different from the laws and protections in your country. When we engage a third-party service provider, we require that its privacy and security standards adhere to this Privacy Statement and applicable privacy laws.

Exercising Your Privacy Rights

You may make a request at any time to exercise your privacy rights listed above by contacting us at client.support@stem.com. We will respond to your request within 30 days of receipt (if properly submitted). If we need more time to process and respond to your request, we will notify you of that fact along with the reason for the delay. In all cases we will complete your request within 60 days of the date of receipt of your properly submitted request. If we decline to take action regarding your request, we will inform you of our decision and the reason for it, along with instructions on how you may appeal our decision.

Do We Update Our Privacy Statement?

We may update this Privacy Statement from time to time. If we make changes, we will notify you by revising the date at the top of the Privacy Statement and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage or sending you a notification). We encourage you to review the Privacy Statement whenever you access the services or otherwise interact with us to stay informed about our information practices and the choices available to you.

How Can You Contact Us?

To ask questions about or provide comments to this Privacy Statement and our privacy practices, contact us at:

Stem Headquarters: 1400 Post Oak Blvd. Suite 560, Houston, TX 77056
client.support@stem.com
877-374-7836

Your Privacy Rights

Access. You have the right to know what personal information Stem has collected about you. Our Privacy Statement details the personal information we collect about all consumers generally. If you would like to access the specific personal information that we have collected from you, please submit a request.

Deletion. You have the right to request that we delete personal information we have collected from you, subject to certain exceptions. For example, we will not delete any personal information required to provide our services to you or that we must maintain to comply with our legal obligations. We will notify you if we are unable to delete any of your personal information following receipt of your request.

Correction. You may request that we correct inaccurate information we maintain about you, subject to some exceptions and, if necessary, independent verification.

Opt-Out of the Sale/Sharing of Your Personal Information. Stem does not sell or share personal information outside the purpose for which it is collected. Should Stem change its policy of not selling or sharing personal information outside of the purpose for which it is collected, you will have the right to opt out of the sale or sharing of that personal information.

Limitation. In some instances, you have the right to limit our use or disclosure of Sensitive Personal Information.

Non-Discrimination. Many U.S. state privacy laws provide the right not to be discriminated against if you exercise any of the rights outlined in this Privacy Statement. Please note that many U.S. state privacy laws provide that a legitimate denial of a request for information, deletion, or to opt out is not discriminatory, nor is charging a fee for excessive or repetitive consumer requests.

Exercising Your Rights

To make an access, deletion, correction, or limitation request, please use our online request form/portal (https://www.stem.com/privacy/), email us at client.support@stem.com or call us at 877-374-7836.

Data Protection Officer

In alignment with EU General Data Protection Regulation (GDPR) and German Federal Data Protection Act (BDSG), we maintain a Data Protection Officer –https://dsbplus.de/kontakt.htm.