Privacy Policy

In our effort to provide you the best possible customer experience we collect and use some personal information about you. This Privacy Policy explains how ThompsonGas, LLC and its affiliates and d/b/a’s, including Como Oil & Propane, North Shore Oil & Propane, Quality Propane, ER Energy and Propane Northwest (collectively “ThompsonGas” “we” or “us”) may work with, collect, store, use, or disclose personal information we receive through your use of our residential and commercial services, including but not limited to our propane services, website, mobile applications, and other online services we offer or that we have linked to this Privacy Policy (collectively, the “Services”). As explained in this Policy, we provide you choices about the collection and use of your information. Please read this Privacy Policy carefully before you start to use our Services, whether online or offline.

We value your privacy and we take it seriously. We use your Personal Information to provide our Services in alignment with your preferences, to process your requests and orders, to contact you regarding products and services which may be of interest to you, and to carry out relevant administrative services. We do not sell your Personal Information to third parties without your obtaining necessary consent or providing disclosures required by applicable law.

By using our Services, you understand that we may revise and update this Privacy Policy from time to time in our sole discretion. Where appropriate, we may seek to provide advance notice before an updated Privacy Policy becomes effective. You agree that we may notify you of the updated Privacy Policy by posting it on our websites or customer account portal, and that your use of the online Services after the effective date of the updated Privacy Policy (or engaging in such other conduct as we may reasonably specify) constitutes your agreement and consent to do business with us in accordance with the updated Privacy Policy and, as applicable, the Website Terms of Use. It is your responsibility to check the Privacy Policy posted on our websites and customer account portal periodically so that you are aware of any changes, as they are binding on you.

By using our online Services, you represent and warrant that you are over 18 years of age and are of legal age to form a binding contract with ThompsonGas.

PERSONAL INFORMATION WE COLLECT

Definition of Personal Information. When we refer to the term “Personal Information,” it includes any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, including any information that is subject to applicable data protection laws, including “nonpublic Personal Data” as defined under the Gramm-Leach-Bliley Act (“GLBA”), “Personal Information” as defined under the California Consumer Privacy Act, Cal. Civ. Code §§ 1798.100 to 1798.199 (“CCPA”) and “Cardholder data” as defined under Payment Card Industry Data Security Standard (“PCI DSS”).

Examples of Personal Information include but are not limited to: first and last name, postal address, email address or other online contact information (such as an online user ID), telephone number, date of birth, Social Security number (or its equivalent), driver’s license number or other government-issued identification number, financial account information, payment card data (including primary account number, expiration date, service code, full magnetic stripe data or equivalent on a chip, CAV2/CVC2/CVV2/CID and PIN number), access code, password, security questions and answers, medical information, Internet Protocol (IP) address or any other unique identifier.

CATEGORIES OF PERSONAL INFORMATION WE COLLECT

Currently, we may collect the following types of Personal Information about users of our online and offline Services:

• Identifying and contact details. Name, user/account name and passwords, signature, postal address, unique personal identifiers, online identifiers, internet protocol addresses (“IP addresses”), email addresses, telephone number, social security numbers, driver’s license numbers, or similar identifiers.
• Financial and payment information. In order to process payments or refunds for the Services and process your application for credit terms, if applicable, we will collect certain financial and payment information, such as credit card or other financial account information, checks, and billing address, and utilize third-parties to process payments and credit applications who as part of their processes store the applicable financial and payment information.
• Demographic information. If you create an account with us, apply for credit, or choose to provide information through promotions or other methods, we may request that you provide demographic information. For example, we may request your age, birth date, gender and zip code.
• Communications. When you communicate with ThompsonGas — for example, by emailing us, calling our office, or participating in a contest, survey, or sweepstakes offering – we may record and store the information you provide. 
• Internet activity. We collect information about how you interact with our websites and advertisements.
• Social Media Information. We may collect information you post on our social media pages, including publicly available social media profile information related to your posts.
• Purchase and Order Information. When you make orders and purchase services from us, we collect information related to your orders, preferences, purchase history, service history, and any contracts we may have with you.
•  Cookies and similar technologies: 
  • “What’s a cookie?” When you visit one of our websites or otherwise utilize our online Services, we may use “cookies” which are small text files stored on your computer or device. These “cookies” and other similar technologies like pixels, web beacons (also known as “clear GIFs”) and local storage may be used to provide features to you and to collect information about how you use our Services and navigate through our websites.
  • Advertising cookies. We may ask advertisers or other partners to serve ThompsonGas ads or services to your devices, which may use cookies or similar technologies placed by us or the third party. If you click on ThompsonGas ads on other websites, you will be directed to a ThompsonGas website, and we may keep track of how you arrived at our website to help us serve better ads in the future.
• Analytics information. We use third-party analytics companies on our websites to collect and process certain usage data, including Google Analytics. See Section 2, “How We Use Your Information,” below, for more information about our use of analytics and your related choices.
• Physical location. When you use our websites or mobile services, we may use and store GPS and cell tower information relating to your mobile device, in combination with other location-based information such as your IP address, your billing postal code provided by your carrier, or your registration location, to provide enhanced location-based services, including delivery of Services to your current location, and to serve location-targeted advertising for ThompsonGas, search results, and other content.
• Log file information.
  • Log file information may be automatically reported by your browser each time you make a request to access (i.e., visit) our websites or mobile services. It can also be provided when the content of the Services is downloaded to your browser or device.
  • When you use our websites or mobile services, our servers automatically record certain log file information, including your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Services, domain names, landing pages, pages viewed, and other such information. We may also collect similar information from emails sent to our Users which then help us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Services.
• Mobile device unique identifier. When you use a mobile device to connect to our Services via a service provider that uniquely identifies your mobile device, we may use this unique identifier to offer you extended services and/or functionality. Certain Services may require the collection of your mobile phone number. We may associate that mobile phone number with the mobile device unique identifier.

If a visitor does not want information collected through the use of cookies, most browsers allow the visitor to reject cookies. We may share non-Personal Information obtained via cookies with our advertisers and affiliates.

• Location information. We may collect your address, zip code, and—depending on your device settings—we may also collect precise geolocation information. You can adjust the settings of your mobile device at any time to control whether your device communicates this location information. See your device instructions to learn more about these settings.
• Cameras. We operate video cameras at ThompsonGas physical locations for security, safety, and operational purposes.
• Tank telemetry. If your propane tank is equipped with a tank monitor, we work with a third-party to collect information about the location of the tank, in addition to collecting tank telemetry. This helps us to better monitor the propane remaining in your tank and to better service your propane needs.
• Information from third parties. We may receive information about you, including Personal Information, from third parties to supplement the information we maintain about you. If we do so, this Policy governs any combined information that we maintain in personally identifiable format.

HOW WE USE YOUR PERSONAL INFORMATION

We use the categories of Personal Information collected about you to enhance our Services and your customer experience and for the purposes described below:

• Managing our relationship with you, including communicating with you and responding to your communications;
• Providing you with your requested Services and customer support;
•  Processing payments or refunds for the Services and processing your application for credit terms, if applicable;
•  Complying with third-party contracts;
•  Complying with our legal or regulatory obligations and managing potential litigation;
•  Helping you efficiently access your information after you sign-in;
•  Remembering information so you will not have to re-enter it during your visit or the next time you visit the Services;
•  Providing personalized content and information to you and others, which could include online ads or other forms of marketing;
•  Providing, improving, testing, and monitoring the effectiveness of the Services;
•  Developing and testing new products and features;
•  Monitoring metrics such as total number of visitors, traffic, and demographic patterns; or
•  Diagnosing or fixing technology problems.

We may use Personal Information for any purpose otherwise allowed by applicable law. We may also make use of all information acquired through the Services that is not Personal Information, such as aggregate data.

WE USE GOOGLE ANALYTICS AND OTHER ANALYTICS TOOLS

We use Google Analytics and other analytics providers to collect information about how users interact with our Website. ThompsonGas uses the data obtained through Google and other analytics providers to understand how users interact with our websites so that we can improve our Services. The information collected for this purpose (including your IP address or other information collected by automated means, like cookies) will be disclosed to or collected directly by the analytics providers. Please note that the information generated by analytics cookies will be transmitted to and stored by Google on its servers located in the United States.

ThompsonGas’ policy is not to utilize or store the analytics information it receives about the use of our Services in a way that identifies directly any particular individual.

Google will use this information on behalf of ThompsonGas for the purpose of analyzing your use of the Website, compiling reports on Website activity for Website operators and providing them other services relating to Website activity and internet usage. The IP address that your browser conveys within the scope of Google Analytics will not be associated with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser; please note, however, that if you do this you may not be able to use the full Website. Google currently provides options and tools to opt out of being tracked by Google Analytics. Currently, these options include downloading and installing ‘Google Analytics Opt-out Browser Add-on’ for your current web browser: https://tools.google.com/dlpage/gaoptout.

To learn more about Google’s privacy practices and any opt-out choices Google Analytics offers, visit: https://support.google.com/analytics/answer/181881?hl=en.

DISCLOSURE OF YOUR PERSONAL INFORMATION

We do not sell your Personal Information to third parties without obtaining necessary consent or providing disclosures required by applicable law.

We may share your Personal Information with the following third parties or service providers for the purposes described below:

• We may either employ or partner with third-party companies for the purposes of advertising, facilitating, or enhancing our Services. In order for these third-party companies to carry out their services, your Personal Information and other data collected may be shared with these third-party companies (including, without limitation, maintenance services, database management, web analytics and improvement of our Services).
• We may employ partners or third-party companies to process payments, refunds, or credit applications, and to assist with collections.
• We may utilize third-party call centers to respond to your inquiries and Services-related requests.
• We may engage with independent contractors to carry out Services on our behalf, such as independent contractor drivers we may hire from time to time to delivery orders. In order for the independent contractors to complete Services, your Personal Information may be shared with them to the extent necessary to carry out Services.
• Government, courts, and law enforcement –
  • We will access, preserve, and share any information about you, without your consent, to government or law enforcement officials or private parties if we, in good faith, believe it is necessary or appropriate to do so to respond to claims and legal process (including, but not limited to, subpoenas), to comply with applicable laws, to protect the property and rights of ThompsonGas, you or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to pose a risk of being, or is illegal, unethical or legally actionable. This may include responding to legal requests from jurisdictions outside of the United States where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards.
  • We may also access, preserve and share information when we have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; protect the legal rights and property or safety of ourselves, you or others, including as part of investigations; and prevent death or imminent bodily harm. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.
• We may also disclose your Personal Information with your permission.

HOW WE STORE AND PROTECT YOUR INFORMATION

We care about the safety and security of your information. ThompsonGas employs data collection, storage and processing practices and security measures designed to protect Personal Information against unauthorized access, alteration, disclosure or destruction. Where appropriate, we use firewalls and limits on who can access databases that store Personal Information.

Please keep in mind that it is not possible to achieve a perfect state of data security. Although we maintain reasonable administrative, physical and electronic security measures designed to protect your Personal Information from unauthorized access, we cannot ensure absolute security of any information you transmit to us or guarantee that this information will not be accessed, disclosed, altered, or destroyed. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your un-encrypted electronically stored Personal Information. To the extent the law of your jurisdiction allows for notification of a breach via e-mail or conspicuous posting on the Services, you agree to accept notice in that form.

By using our websites and/or registering for and using the Services, you consent to the transfer of information to anywhere where the Services or its Service Providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

YOUR CHOICES ABOUT YOUR INFORMATION AND COMMUNICATION PREFERENCES

ThompsonGas provides customers with a variety of options to communicate with ThompsonGas and address questions about an account or Service, including updates to your profile/privacy settings. For example, we may contact you by telephone, email, text (SMS) message, auto-dial, or prerecorded call regarding ThompsonGas, promotions and marketing, account and payment information, the Services, including, technical, safety, and security notices.

We have built controls and policies in place to ensure that before contacting you we have obtained any necessary consents in order to comply with applicable law and in an effort to respect your preferences. ThompsonGas has also created policies and procedures for customers to manage their communication preferences. By logging into your account at https://www.thompsongas.com or by contacting your local district office you can choose whether you want to receive certain informational and/or marketing email, text message, and/or automated or prerecorded calls from ThompsonGas. For example:

• Text messaging – You may opt-out of receiving text messages by replying “STOP” to any text message received.
• Emails – In all promotional emails, you will be given the opportunity to opt-out of receiving such messages in the future by clicking on the link at the bottom of the email that says “unsubscribe.” It may take up to ten (10) business days for us to process your opt-out request.
• Cookies – If a visitor does not want information collected through the use of cookies, most browsers allow the visitor to reject cookies.
• Mobile device unique identifier – Unless you choose to opt out, we may also share your mobile phone number with certain select third parties. You can opt out by changing the privacy settings on your cell phone.

Please note that we reserve the right to send you Services-related communications (e.g., account verification, payment confirmations, technical and security notices) by email, mail, or live telephone call that you may not opt out of. Even if you have unsubscribed from receiving promotional emails from us, we may send you other types of important email communications without offering you the opportunity to opt-out of receiving them, such as relevant customer service announcements and administrative notices.

YOUR PERSONALIZED ADVERTISING CHOICES

When you leave our websites, you may continue to see our ads on third-party websites we do not control. This personalized advertising is handled by service providers that automatically collect information about you on our websites and third-party websites using technology like cookies. You may be able to opt out of receiving personalized advertisements on this browser or device from advertisers, or advertising networks who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out options of each of those organizations. Links to those sites are here:

Network Advertising Initiative:
• Browser Opt-Out: http://www.networkadvertising.org/choices/
Digital Advertising Alliance:
• Browser Opt-Out: http://www.aboutads.info/choices/
Both Network Advertising Initiative and Digital Advertising Alliance
• App Opt-Out: http://youradchoices.com/appchoices

You may also be able to change your mobile device settings to opt out of personalized advertising through apps by consulting your device’s settings. When you opt out of personalized advertising, you may continue to see online advertising on the Services and/or our ads on other websites and online services.

WHAT HAPPENS IN THE EVENT OF A CHANGE OF CONTROL

We may share all or some of your Personal Information with any of our subsidiaries, joint ventures, or other companies under common control to be used in a manner consistent with this Notice. Additionally, in the event we go through or undergo due diligence in anticipation of a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information may be among the assets transferred. You acknowledge that such transfers may occur and are permitted by this Privacy Policy, and that any entity that acquires such Personal Information by transfer may continue to process your Personal Information as set forth in this Notice.

If we transfer part or the whole of ThompsonGas or our assets to another organization, your information such as name, email address, payment and billing information and any other information ThompsonGas has collected may be among the items transferred. The buyer or transferee will have to honor the commitments we have made in this Privacy Policy.

CHILDREN’S PRIVACY

ThompsonGas does not knowingly collect or solicit any information from anyone under the age of 17, knowingly allow such persons to register for the Services, or knowingly sell the personal information of such persons. The Services and their content are not directed at anyone under the age of 17. In the event that we learn that we have collected personal information from someone under age 17 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about anyone under 17, please contact ThompsonGas at www.thompsongas.com/contact-us/.

IF YOU ARE A CALIFORNIA RESIDENT UNDER THE AGE OF 18, DO NOT SHARE ANY PERSONAL INFORMATION ON ANY FORUM OR MESSAGE BOARD. If you do post any Personal Information, you can remove it using Services functionality. This removal may not be complete given the nature of the Internet. You may contact us for assistance.

HOW WE RESPOND TO DO NOT TRACK SIGNALS

It is not ThompsonGas’ policy to track its users over time and across third-party websites to provide targeted advertising. Do Not Track (DNT) is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. ThompsonGas does not respond to Do Not Track (DNT) signals and handles all user information consistent with this Privacy Policy.

OTHER WEBSITES AND SERVICES

The Services may contain links to other websites or services that we do not own or operate. We are not responsible for the practices employed by any websites or services linked to or from the Services, including the information or content contained within them. Your browsing and interaction on any third-party website or service, including those that have a link on our Services, are subject to that third party’s own rules and policies, not ours.

INTERNATIONAL CONSIDERATIONS

We have developed data practices designed to assure information is appropriately protected but we cannot always know where personal information may be accessed or processed. While our primary data centers are in the United States, we may transfer personal information or other information to our affiliates’ offices outside of the United States. In addition, we may employ other companies and individuals to perform functions on our behalf. If we disclose personal information to a third party or to our affiliates’ employees outside of the United States, we will seek assurances that any information we may provide to them is safeguarded adequately and in accordance with this Privacy Policy and the requirements of applicable privacy laws.

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your personal data by us from your region to countries which do not have data protection laws that provide the same level of protection that exists in countries in the European Economic Area, including the United States. By providing your Personal Information, you consent to any transfer and processing in accordance with this Policy.

NEVADA PRIVACY RIGHTS

Although ThompsonGas does not sell personal information, Nevada residents have the right to request that a company not sell their personal information. This right applies even if their personal information is not currently being sold. If you are a Nevada resident, and would like to submit such a request, you can do so by calling sending an email to www.thompsongas.com/contact-us/ or by calling us toll-free at1-833-746-7527. You may also submit a request by mail to:

ThompsonGas, LLC
Attn: IT Dept. – Nevada Privacy Request
5260 Westview Drive, Suite 200
Frederick, MD 21703

CALIFORNIA PRIVACY RIGHTS

• CALIFORNIA SHINE THE LIGHT LAW
  If you are a California resident and a current ThompsonGas customer, one time per year you can request a notice disclosing the categories of personal information we have shared with third parties – if any – for the third parties’ direct marketing purposes, during the preceding calendar year. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information covered by the Shine the Light law will be included in our response.To request a notice, please submit your request by mail to:

ThompsonGas, LLC
Attn: IT Dept. – California Privacy – Shine the Light Request
5260 Westview Drive, Suite 200
Frederick, MD 21703

You may also submit a request to us by email to www.thompsongas.com/contact-us/. Please include “California Privacy – Shine the Light Request” in the subject line of your email. Please also include your name, mailing address, and current account number in the body of your email or letter.

If you are a California resident, we will provide the requested information to you at your email address if we have your email address on file. Please allow 30 days for a response.

• CALIFORNIA CONSUMER PRIVACY ACT
  The California Consumer Privacy Act, California Civil Code Sections 1798.100 et seq., as amended (“CCPA”), provides residents of the State of California several rights related to the collection, use, and disclosure of personal information collected by certain businesses. These California Privacy Rights include: rights of access and disclosure, a right to request deletion, a right to opt-out of the sale of information, and a right to nondiscrimination. Businesses that collect consumers’ personal information must comply with consumers’ requests consistent with the requirements of the CCPA. Some exceptions apply, as set forth in the CCPA; if we decline to take action upon a request, we will notify you of the reasons why. If we fulfill a request for access or disclosure of personal information, we will deliver the requested information electronically or by mail, free of charge. We are not required to respond to a consumer’s requests for access or disclosure of personal information more than twice in a 12-month period.

NO SALE OF PERSONAL INFORMATION
ThompsonGas has not sold Personal Information in the 12-month period immediately preceding the effective date of this Privacy Policy.

ACCESS TO YOUR PERSONAL INFORMATION

You have the right, subject to certain exceptions defined in the CCPA and other applicable laws and regulations, to request that we disclose certain information to you about the collection and use of your Personal Information over the past twelve (12) months. This right includes information about:

• Categories of Personal Information we collect about you.
• Categories of sources for the Personal Information we collect about you.
• Our business or commercial purpose for collecting that Personal Information.
• The categories of third parties with whom we share that Personal Information.
• The categories of Personal Information that each recipient received.
• The specific pieces of Personal Information we collected about you.

RIGHT TO REQUEST DELETION OF PERSONAL INFORMATION
You have the right, subject to certain exceptions defined in the CCPA and other applicable laws and regulations, to request that we delete any of your Personal Information we have collected from you and retained, subject to certain exceptions.

EXERCISING YOUR RIGHTS
To exercise the CCPA rights described above, please submit a consumer request to us by either:
• Calling us toll-free at 1-833-746-7527;
• Visiting www.thompsongas.com/ccpa after January 1, 2020, where you can submit a request online through our web portal; or
• Sending us a request by mail to:

ThompsonGas, LLC
Attn: IT Dept. – California Privacy Request
5260 Westview Drive, Suite 200
Frederick, MD 21703

In order for us to process this request you must:

• Provide sufficient information to allow us to verify, to a reasonably high degree of certainty, that you are the person about whom we collected Personal Information. This includes providing us with multiple pieces of Personal Information to match against Personal Information about you that we may or may not maintain and which we have determined to be reliable for the purpose of verification. We will only use Personal Information provided in a verifiable consumer request for the purpose of verifying the requestor’s identity or authority to make the request.
• Describe your request with sufficient detail to enable us to understand, evaluate, and respond to your request.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity, confirm your authority to make the request, and confirm that the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us.

Please note that we will not accept more than two verifiable consumer requests within a 12-month period.

AUTHORIZED AGENT
Only you, or a person you have designated in writing as your authorized agent, or who is registered with the California Secretary of State to act on your behalf, or whom you have provided power of attorney pursuant to California Probate Code sections 4000 to 4465 (“Authorized Agent”), may make a verifiable consumer request related to your Personal Information. Although individuals under the age of 18 are not permitted to use our Services and we do not knowingly collect the Personal Information of children, you have the right to make verifiable consumer requests on behalf of your minor child.

If you wish to have an Authorized Agent make a verifiable consumer request on your behalf, the Authorized Agent must provide us with sufficient written proof that you have designated him or her as your Authorized Agent. In addition to such proof, you must still provide sufficient information to allow us to reasonably verify that you are the person about whom we collected Personal Information.

NON-DISCRIMINATION
You have the right not to receive discriminatory treatment for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you services.
• Charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of service.
• Suggest that you may receive a different price or rate for services or a different level or quality of services.

From time to time, we may offer you certain financial incentives permitted by the CCPA as compensation for the collection, sale, or deletion of Personal Information. If we do so, we will provide you with notice and collect your opt-in consent consistent with the requirements of the CCPA.

HOW TO CONTACT US REGARDING OUR PRIVACY POLICY

We encourage you to visit or create an online account at www.thompsongas.com, where you can access account information.
You may also direct questions or concerns about this Privacy Policy by contacting us as follows:

Calling us at toll-free at 1-833-746-7527.

Mailing address:
ThompsonGas, LLC
Attn: IT Dept. – California Privacy Request
5260 Westview Drive, Suite 200
Frederick, MD 21703

OMISSIONS & TYPOS

ThompsonGas tries very hard to make certain all of the information provided on our website is accurate, however we are not responsible for typographical errors, omissions or technical inaccuracies. 

CHANGES IN THE THOMPSONGAS PRIVACY & SECURITY POLICY

It is understood that you acknowledge these policies as part of the terms of service to use ThompsonGas.com. If you do not agree, please do not use this site. ThompsonGas reserves the right to change these terms and policies at any time. If we do decide to make any changes, we will post these changes on our site in order to make you aware.