LG&E and KU privacy policy

PRIVACY NOTICE
NOTICE FOR OUR CUSTOMERS

Louisville Gas and Electric Company (“LG&E”) and Kentucky Utilities Company (“KU”) (referred to collectively in this notice as “LG&E and KU,” “we,” “us,” or “our” and, as it applies to you, the company from which you receive utility service) developed this Privacy Notice (“Notice”) to make our customers (referred to as “Users,” “you” or “your”) familiar with how we collect, use, and disclose information. This Notice describes our practices in connection with information that we collect, including, but not limited to, through the following:

• Websites operated by us or certain third-party service providers acting on our behalf (collectively, the “Websites”);
• Our social media pages (collectively, our “Social Media Pages”);
• Mobile applications operated by us or certain third-party service providers acting on our behalf;
• HTML-formatted email messages that we send to you that link to this Notice or other communications with you; and
• Advanced metering infrastructure (“AMI”)

Collectively, we refer to the Websites, Social Media Pages, mobile applications, text messages, emails, and AMI as the “Services.”

By providing any information to us, and by accessing and using Services, you agree that you have read and understand this Notice and that you accept and consent to the privacy practices and uses or disclosures of information about you that are described herein.

Note: This Notice represents LG&E and KU’s general privacy notice. If a customer provides information to a third party with whom they have a relationship, LG&E and KU’s privacy policy does not apply. Such a relationship would be subject to the privacy policy of the third party.
 

PERSONAL INFORMATION

For purposes of this Notice, “Personal Information” is information that identifies you as an individual or relates to an identifiable individual. The Services may collect Personal Information, including but not limited to:

• Name
• Postal and/or service address
• Telephone number
• Email address
• Date of birth along with other information that identifies you as an individual
• Social Security number
• Driver’s license number
• Taxpayer identification number
• Passport number
• Bank account information
• Payment card data
• Payment plan information
• Transaction, billing, and payment history 
• Account number, email address, username and password
• Energy information, such as electricity kWh usage, natural gas or electricity supplier, and/or rate class along with other information that identifies you as an individual
• Personal characteristics such as photographic image, fingerprints, handwriting or other unique biometric data
• Website(s) and other Services usage information that identifies you as an individual

Collection of Personal Information

We and our service providers collect Personal Information in a variety of ways, including:

• Through the Services.
  • We collect Personal Information through the Services, for example, when you create or register an account to access the Services, pay your utility bills, track your utility usage, apply for a rebate, report an outage, fill out customer agreements or other forms, enter sweepstakes or contests, complete a survey, contact customer service, or fill out an order form.
     
• From Other Sources.
  • We receive your Personal Information from other sources, for example:
    • from third party service providers, when they share your energy management system, devices, or appliance information.
    • joint marketing partners, when they share Personal Information with us.
  • If you connect your social media account to your Services account, you will share certain Personal Information from your social media account with us, for example, your name, email address, gender, photo(s), interests, number of followers, and list of social media contacts, and any other information that may be, or you make, accessible to us when you connect your social media account to your Services account. By linking to your social media account, you consent to LG&E and KU’s linking of your account to your identity, household, device, browser, or other identifier, including publicly available data or data provided directly by you to us. If you later unlink your social media accounts, we will retain the Personal Information we received up to that time from the social media platform.

We need to collect Personal Information to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Notice.

Use of Personal Information

We and our service providers use Personal Information for the following purposes:

• Contacting you.
   
• Providing the Services and fulfilling your requests.
  • To provide the Services to you, such as arranging access to your registered account(s), maintenance of your registered account(s), or providing you with related benefits, special promotions, information relating to LG&E and KU and the Services or customer service.
  • To respond to your inquiries and/or fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request a quote for or other information about our Services or our business.
  • To provide information relating to the Services, such as regarding service outages and restoration, for example through email updates, texts alerts, and pre-recorded calls.
  • To complete your transactions, verify your information, and provide you with related benefits, special promotions, or customer service.
  • To send administrative information to you, such as changes to our terms, conditions, and policies.
     
• Providing you with our newsletter and/or other marketing materials and facilitating social sharing.
  • To send you marketing-related emails, with information about our services, new products, and other news about our company or business.
  • To facilitate social sharing functionality that you choose to use.
     
• Analyzing Personal Information for business reporting and providing personalized services.
  • To analyze or predict our Users’ preferences.
  • To better understand your interests and preferences, so that we can allow for personalized interactions with you, provide information and/or offers tailored to your interests, and deliver content via our Services that we believe will be relevant and of interest to you.
     
• Allowing you to participate in sweepstakes, contests, or other promotions.
  • We may offer you the opportunity to participate in a sweepstakes, contest, or other promotion.
  • Some of these promotions have additional rules or terms containing information about how we will use and disclose your Personal Information. Please read those additional rules or terms before choosing to participate.
     
• Aggregating and/or anonymizing Personal Information.
  • We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual. We may use such aggregated and/or anonymous Personal Information to create business and marketing insights to improve our business.
     
• Helping us plan, deploy, improve, protect and defend our energy grid and network infrastructure, protecting our property and legal rights, and for other lawful purposes.
   
• Accomplishing our business purposes.
  • For data analysis, for example, to monitor usage, traffic, and improve the efficiency of our Services;
  • For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements;
  • For security purposes including efforts to prevent and investigate illegal activities and violation of this Notice, fraud prevention and fraud security monitoring, for example, to detect and prevent cyber-attacks, ransomware attacks, or attempts to commit identity theft;
  • For developing new products and services;
  • For enhancing, improving, repairing, replacing, maintaining, or modifying our current products and services, as well as undertaking quality and safety assurance measures;
  • For identifying usage trends, for example, understanding which parts of our Services are of most interest to Users; 
  • For billing purposes, including reporting and collecting debts;
  • For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our Users; and
  • For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our Users so we can focus our energies on meeting our Users’ interests.

Where we disclose Personal Information to our service providers for a purpose set forth herein, we enter a contract with the third-party that describes the purpose and requires the third party to both keep Personal Information confidential and not use it for any purpose except performing under the contract.

We will not use your Personal Information to target, segment, or profile individuals based on health (including pregnancy), negative financial status or condition, political affiliation or beliefs, racial or ethnic origin, religious or philosophical affiliation or beliefs, sexual orientation or gender identity, trade union membership, data relating to alleged or actual commission of a crime, or for any unlawful or discriminatory purpose or in a manner that would be inconsistent with your reasonable expectation of privacy. We will not use Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you with notice and/or updating this Notice.

Disclosure of Personal Information

In accordance with applicable law, we disclose Personal Information:

• To our affiliates and subsidiaries for the purposes described in this Notice.
• To our service providers, to facilitate services they provide to us.
  • These can include providers of services such as website hosting, data analysis, payment processing, order fulfillment, return authorization, fraud prevention, information technology and related infrastructure provision, customer service or related benefits (including special promotions), email delivery, auditing, and other services.
• To third parties, consistent with your choices, to permit them to send you marketing communications, unless you opt-out from marketing communications.
• To third party sponsors of sweepstakes, contests, giveaways, and other promotions.
• By using the Services, your Personal Information may be disclosed in the following circumstances:
  • When you ask us to allow another person (i.e., a relative) to access your account.
  • When you ask us to share your account information with a third party to monitor energy usage data.
  • As permitted by law to perform credit checks, report or collect debts owed, or protect the rights or property of LG&E and KU, our Services, and our Users.
  • Through your social sharing activity. When you connect your Services account to your social media account(s), you will share information with your friends associated with your social media account(s), with other users, and with your social media account provider(s). By doing so, you authorize us to facilitate this sharing of information, and you understand that the use of shared information will be governed by the social media provider’s privacy policy.

Other Uses and Disclosures

We also use and disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:

• To comply with applicable law and regulations.
  • This may include laws outside your jurisdiction.
     
• To cooperate with law enforcement.
   
• When legally compelled.
  • When we are contractually obligated to disclose your information;
  • To share energy usage data with energy suppliers as required by law;
  • To enforce our terms and conditions; and/or
  • To protect our rights, privacy, safety or property, and/or that of our affiliates or subsidiaries, you or others.
     
• In connection with a sale or business transaction.
  • We have a legitimate interest in disclosing or transferring your Personal Information to a third party when we evaluate or conduct any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock.
     

OTHER INFORMATION

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Services collect Other Information such as:

• Browser and device information
• Information collected through cookies, pixel tags and other technologies
• Demographic information and other information provided by you that does not reveal your specific identity
• Information that has been aggregated in a manner such that it does not reveal your specific identity

Collection of Other Information

We and our service providers may collect Other Information in a variety of ways, including 

• Your browser or device.
  • Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services you are using, the referring page that linked you to the Services, the pages, content, or ads you see or click on during your visit and when and for how long you do so, items you download, the next Web site you visit when you leave the Services, and any search terms entered on the Services or a referral site. We use this information to ensure that the Services function properly.
     
  • We use a heat mapping tool that provides graphical representation of where visitors to our Services have clicked and scrolled down to. It can also show from which pages visitors have been referred to on the website. Cookies placed by the computers of visitors on the Services do not include or collect Personally Identifiable Information.
     
  • To improve the customer service you experience at our Site, we use a third-party usage monitoring analytics tool, that tracks page content and click/touch, movement, scroll, and keystroke activity at our Site and captures the screen displays of your clicks, mouse movements, scrolls and forms that you see on our Site as you navigate. This technology associates this information with your name, LG&E and KU account number, address and any online customer feedback surveys you have completed. This technology does not capture sensitive information that you input into forms such as payment card numbers, bank account numbers and Social Security numbers. We review these captured experiences to identify things that we can improve on our Site and in the service that we provide to you.
     
• Cookies.
   
  • Cookies are pieces of information stored directly on the computer that you are using. Our Services use session ID cookies and persistent cookies. A session ID cookie is temporary and allows users to complete a form. Once you close your browser, the cookie terminates. A persistent cookie is stored on a device’s hard drive for an extended period and can be removed by following Internet browser “help” file directions. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other usage and traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them. Cookies further allow us, or may also be used by our marketing partners, to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Services. We may also use cookies or other technologies in online advertising to track responses to our ads. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. You may also wish to refer to https://allaboutcookies.org/how-to-manage-cookies or visit the Network Advertising Initiative’s website at https://thenai.org/opt-out/ for more information. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services. You also may not receive advertising or other offers from us that are relevant to your interests and needs. Our Site uses Google Analytics, including its associated cookies, to collect and analyze Site traffic and usage information. As such, Google may retain and use, subject to the terms of its privacy policy (located at https://policies.google.com/privacy), information collected from your use of this Site. To opt-out of your Site usage being included in our Google analytics reports, you may follow these instructions.
     
• Pixel tags and other similar technologies.
   
  • Pixel tags. Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates. Some of our third-party service providers who provide data analytics services through our Services use pixel tags to collect standard internet log information and web site user behavior.
     
  • Invisible reCAPTCHA. We use Google’s invisible reCAPTCHA application on our Services to protect against spam and other automated abuse. The reCAPTCHA tool may make use of cookies, as well as other information like IP address, date, time, language, screen size and resolution, and mouse movements. The use of the reCAPTCHA tool and any information collected through the tool are subject to Google’s privacy policy, available at https://policies.google.com/privacy, and Google’s terms of service, available at https://policies.google.com/terms?hl=en.

Uses and Disclosures of Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
 

SECURITY

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.
 

CHOICES AND ACCESS

Your choices regarding our use and disclosure of your Personal Information

We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt out from:

1. Receiving marketing-related emails from us. If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt out at any time by using the unsubscribe feature included in any such message. Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative and transactional communications, from which you cannot opt out.
2. Receiving text/SMS/mobile messages from us. If you no longer want to receive text/SMS/mobile messages from us on a going-forward basis, you may opt out at any time by contacting LG&E and KU, in accordance with the “Contact Us” section below, or by responding “STOP” to any such message.
3. Our sharing of your Personal Information with affiliates or subsidiaries for their direct marketing purposes. If you would prefer that we discontinue sharing your Personal Information on a going-forward basis with our affiliates or subsidiaries for their direct marketing purposes, you may opt out of this sharing by checking the appropriate box when the data is collected, or at any time by contacting LG&E and KU, in accordance with the “Contact Us” section below.
4. Our sharing of your Personal Information with unaffiliated third parties for their direct marketing purposes. If you would prefer that we discontinue sharing your Personal Information on a going-forward basis with unaffiliated third parties for their direct marketing purposes, you may opt out of this sharing by checking the appropriate box when the data is collected, or at any time by contacting LG&E and KU, in accordance with the “Contact Us” section below.

We will try to comply with your request(s) as soon as reasonably practicable.

How you can access and change your Personal Information

At any time, a User may contact LG&E and KU via postal mail, e-mail, or phone to request:

• a summary of any Personal Information retained by LG&E and KU regarding such User; or
• a change to the User’s personal data record maintained by LG&E and KU.

You may send your requests in accordance with the “Contact Us” section below. We will respond to your request consistent with applicable law. In the event LG&E and KU receives such a request, we may require you to confirm or verify any change to your personal record. Your right to delete your Information is subject to our record retention policies and back-up procedures.
 

THIRD PARTY SERVICES

This Notice does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website, platforms, including social media platforms, mobile apps, or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked website, mobile app, or service by us or by our affiliates or subsidiaries. When you leave the Services, we encourage you to read the privacy statements of each website, mobile app, or service.

We also contract with vendors to provide enhanced customer information to us. These third-party websites are not under the control of LG&E and KU, and we are not responsible for their contents. These websites have separate privacy and data collection practices, independent of LG&E and KU. We are not responsible or liable for these websites’ independent practices, policies, or actions. If you provide any personal information while visiting these websites, you are solely responsible and do so at your own risk.

In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as [Facebook, Apple, Google, Microsoft, RIM], or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other persons or third parties through or in connection with our Social Media Pages. If you connect your social media account to your Services account, you may elect to disclose Personal Information through your social sharing activity:

• you may share certain Personal Information from your social media account with us, for example, your name, email address, photo, list of social media contacts, and any other information that may be or you make accessible to us when you connect your social media account to your Services account.
• you may share information with your friends associated with your social media account, with other users, and with your social media account provider.

By doing so, you authorize us to facilitate this sharing of information, and you understand that the use of shared information will be governed by the social media provider’s privacy policy.
 

THIRD PARTY ADVERTISING

We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services, which are displayed to you based on your activities on the Services.

• You may receive advertisements based on information relating to your access to and use of the Services and other websites or online services on any of your devices, as well as on information received from third parties. When this happens, these third parties automatically receive your IP address. These companies place or recognize a unique cookie on your browser (including through the use of pixel tags), which they may use to measure the effectiveness of their ads and to personalize ad content. They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. We do not have access to or control over cookies or other features that the third-party advertisers may use, and the information practices of these third parties are not covered by our Notice. If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Notice, please visit https://optout.aboutads.info/?c=2&lang=EN and https://optout.networkadvertising.org/?c=1. Please note that you have to opt-out using each of your desktop and mobile browsers and devices separately. Additionally, if you opt-out we may still suggest offerings to you on our Services based on your history with the Services.
   

USE OF SERVICES BY MINORS

The Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from individuals under 18.

JURISDICTION AND CROSS-BORDER TRANSFER

Your Personal Information may be stored and processed in any jurisdiction where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to locations outside of your jurisdiction of residence, including in the United States, which may have data protection rules that are different from those of your country.

SENSITIVE INFORMATION

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (i.e., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background) on or through the Services or otherwise to us.

THIRD PARTY PAYMENT SERVICE

The Services may provide functionality allowing you to make payments to the Company using third-party payment services. When you use such a service to make a payment to us, your Personal Information will be collected by such third party and not by us and will be subject to the third party’s privacy policy, rather than this Notice. We have no control over, and are not responsible for, this third party’s collection, use, and disclosure of your Personal Information.

DISCLAIMER

LG&E and KU makes no guarantee, warranty or representation, express or implied (including implied warranties of merchantability and fitness for a particular purpose), with regard to the accuracy, completeness, usefulness, timeliness or suitability of the information being provided on our Services.

It is expressly understood and agreed that neither LG&E and KU nor its directors, officers, employees or agents shall assume any liability or responsibility for any damages or claims resulting from any use or disclosure of the information being provided on our Services.

UPDATES TO THIS NOTICE

Any modifications to this Notice will be posted in this space and are effective when posted. Continued use of this Site after the Notice is modified constitutes acceptance of the changes. In some cases (for example, if we significantly expand our use or sharing of your Personal Information), we may also tell you about changes by additional means, such as by sending an e-mail to the e-mail address we have on file for you. In some cases, we may request your consent to the changes.

CONTACT US

LG&E and KU welcomes any questions or comments our Users may have regarding this Notice or the use of your Personal Information. Please send your questions or comments to LG&E and KU, attention:

Louisville Gas and Electric Company and Kentucky Utilities Company
Attn: Internet/Privacy Notice, c/o Customer Experience
820 W. Broadway
Louisville, KY
502-589-1444

Because email communications are not always secure, please do not include credit card, a Social Security Number, or other sensitive information in your emails to us.