Privacy Policy
Effective Date: June 24th, 2025
Clara Fortuna LLC (“Clara Fortuna,” “we,” “us,” or “our”) respects your privacy and is committed to protecting personal information. We are a U.S.-based company providing utility data and technology services, and we take data stewardship, ethical conduct, and regulatory compliance seriously. Importantly, Clara Fortuna does not store personal or sensitive data on its servers. When we work with data from our utility clients, we do so within the clients’ existing systems, ensuring that such information remains under the utility's control at all times.
This Privacy Policy describes the information Clara Fortuna collects or handles, how we use and safeguard it, and your rights regarding that information, including your rights under the California Consumer Privacy Act (CCPA). This Policy applies to our website and services, and any personal data processed by Clara Fortuna in the United States.
We limit the personal information we collect to what is necessary for our business purposes. The types of information we may collect or process include:
• Contact Information (Identifiers): When you contact us through our website or by email, we may collect personal identifiers, including your name, email address, phone number, and company or organization details. This information is typically provided by you when you fill out a form or reach out to us with inquiries or for support.
• Website Usage Data (Internet Activity): When you visit our website, we collect certain information automatically through cookies and analytics tools. This may include your IP address, browser type, pages and content viewed, and the dates and times of your visits. This data helps us understand how our Site is used and improve user experience.
• Client Utility Data: In the course of providing services to our utility company clients, we may handle information that our clients provide to us about their customers or operations. This can include utility usage data, account numbers, meter or device data, or other technical and usage information related to utility services. We do not collect this data directly from individuals, and we do not store personal utility customer data on our servers. Instead, we access and analyze it within the client's secure systems as authorized. Any personal information about utility customers remains under the control of the utility company.
We do not intentionally collect sensitive personal information (such as Social Security numbers, financial account info, precise geolocation, or biometric data) through our website. We also do not knowingly collect any personal data from children (see the section on Children's Privacy below).
Clara Fortuna uses the information we collect solely for legitimate business purposes and to serve our clients. Specifically, we may use your information to:
• Provide and Improve Services: Utilize contact information to respond to your inquiries, deliver the requested services or information, and support our utility clients in implementing data analytics or technical solutions. We also use collected data (including Site usage data and client-provided data) to operate, troubleshoot, and improve our services and website functionality.
• Communicate with You: Send you communications related to our services, such as responding to messages you have sent us. We may also send occasional updates about Clara Fortuna, for example, to notify you of new services or improvements, provided that this is permitted by applicable law. You can opt out of marketing communications at any time.
• Security and Fraud Prevention: Utilize information to safeguard our company, clients, and systems. For instance, IP addresses and log data may be used to detect, investigate, and prevent fraudulent or unauthorized activities on our Site. We also maintain audit trails (within client systems) when accessing utility data to ensure accountability and security.
• Legal Compliance: Use and retain information as needed to comply with our legal and regulatory obligations. For example, we may use personal information to fulfill reporting or record-keeping requirements, to respond to lawful requests by public authorities, or to exercise or defend legal claims.
We will not use personal information for purposes that are unrelated to the above or not disclosed to you. In particular, if we handle utility customer data on behalf of a client, we will use that data only to fulfill our contractual obligations to that client and for no other purpose. We do not use client-provided personal data for our marketing or any purpose outside the scope of our services.
Clara Fortuna retains personal information only for as long as necessary to fulfill the purposes described above or as required by law. The retention period depends on the type of information and the context in which it was collected:
• Contact and Inquiry Data: If you contact us or submit information through our Site, we will retain that correspondence and your contact details for as long as needed to respond to you and carry out any related business. For example, if you become a client or partner, we may retain your information as part of our business records. If not, we typically delete or anonymize contact data within a reasonable time after your inquiry is resolved.
• Website Usage Data: Usage data(including cookies, logs, and analytics) is retained for internal analysis and security monitoring purposes. We generally retain analytics data for a standard period (e.g., 12–24 months) to identify trends and improve our Site, unless a longer retention is required (or permitted) by law. Aggregate data that does not identify individuals may be retained for an extended period.
• Client Utility Data: As noted, we do not store utility customer personal data on our systems. Any personal data we handle on behalf of a utility client remains in the client's environment and is subject to that client's retention policies. Suppose we ever temporarily extractor cache such data for analysis (with client approval). In that case, it is retained only for the duration of the analysis or service task and is deleted or returned to the client immediately upon completion. We adhere to our clients' instructions and contractual requirements regarding the return or deletion of their data.
In all cases, when information is no longer needed for the purposes for which it was collected, we will ensure it is securely deleted, destroyed, or de-identified. We periodically review the data we hold and erase or anonymize personal information by our retention policies and applicable law.
We value your privacy and do not sell or rent your personal information to third parties for marketing or monetary purposes. We only share personal information in a few limited circumstances, as described below, and always with appropriate safeguards:
• Service Providers: We may share information with trusted third-party vendors and service providers who perform functions on our behalf to support our operations or the services we provide. This includes, for example, IT hosting providers, website analytics services, or other contractors who have agreed to handle information only for our purposes and under strict confidentiality and data security obligations. These service providers are not permitted to use your information for their purposes.
• Utility Client Personnel: If we are working on a project for a utility client that involves that client's customer data, our work may include sharing insights or results with the client's authorized personnel. In such cases, we act as an extension of the client's team, and the data remains within the client's domain. We do not disclose utility customer information to anyone unauthorized, and our contract with the client, as well as applicable laws, governs the handling of such data.
• Legal Requirements and Protection: We may disclose personal information if required to do so by law or legal process(for example, in response to a subpoena or court order), or when we believe in good faith that disclosure is necessary to protect our rights, enforce our contracts, or ensure the safety of our company, clients, or others. This could include sharing information with regulators or authorities as required by law, or cooperating with an investigation into a security incident.
Aside from the purposes above, we will not share your personal information with third parties unless you have consented to the disclosure. In particular, we do not "sell" personal information as defined under the CCPA and have not sold any personal information in the 12 months preceding the effective date of this Policy. Any information we disclose to third parties is only for legitimate business or legal purposes (also known under the CCPA as" business purposes"), and we ensure that the recipient keeps the information confidential.
Our website uses cookies and similar tracking technologies to provide and improve our online services. Cookies are small text files that a website saves on your device, which can be used to remember your preferences or track your activities on the Site. We use cookies for purposes such as:
• Analytics: We utilize cookies (and third-party analytics tools) to collect information about how visitors use our Site – for example, which pages are most frequently visited, how users navigate the Site, and if any errors occur. This enables us to continually enhance the Site's design, content, and functionality over time.
• Preferences: Some cookies remember your choices (such as your language or other settings) to provide a more personalized and convenient experience on our Site.
• Security: We may use cookies to help identify and prevent security risks or fraudulent activity.
You have control over cookie use. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline or delete cookies if you prefer. Note: If you turn off cookies, some features of our Site may not function as intended. For instance, blocking all cookies might affect our ability to recognize your device or remember your preferences, potentially degrading your user experience.
We do not use cookies to collect personally identifiable information about you for third-party advertising purposes. Additionally, we honor valid "Do Not Track" signals or similar preferences that you may set in your browser, to the extent required by law. For more information about cookies and how to manage them, you can visit the help section of your browser or websites like AllAboutCookies.org.
Clara Fortuna is committed to protecting the security of all information we handle. We implement reasonable and appropriate security measures designed to safeguard personal data from unauthorized access, use, alteration, and destruction. These measures include administrative, technical, and physical controls in line with industry best practices and the sensitivity of the data. Examples of our security practices are:
• Secure Systems: We only work with data on secure, access-controlled systems. For client utility data, we utilize the client's secure infrastructure or other approved secure environments – we do not transfer such data to unapproved systems. Our internal systems are protected by firewalls, up-to-date security software, and encryption where appropriate.
• Access Controls: Personal information is accessible only to those team members who need it to perform their duties. Clara Fortuna has a small team, and each member is trained in confidentiality and bound by strict obligations to protect data. User accounts and credentials are managed to enforce strong passwords and multi-factor authentication where possible.
• Encryption and Transfer Security: We employ encryption and secure protocols (such as HTTPS/TLS) for data in transit, particularly when transmitting sensitive information. For any data at rest in our control (e.g., stored contact emails or documents), we use encryption, access logging, and other safeguards to prevent unauthorized access.
• Monitoring and Testing: We continuously monitor our systems for security events and regularly review our security practices. We also follow our clients’ security requirements when accessing their systems. If we ever detect a potential data breach or security incident, we have procedures in place to respond promptly, mitigate the issue, and notify affected parties as required by law.
Despite our efforts, please note that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security. You can also help by using strong passwords, protecting your own devices and credentials, and alerting us if you suspect any unauthorized access to your or our information.
If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA) (as amended by the CPRA) regarding your personal information. Clara Fortuna is committed to honoring these rights and providing transparency. These rights include:
• Right to Know: You have the right to request that we disclose what personal information we have collected about you. This includes the categories of personal information, the categories of sources from which the information was collected, the business or commercial purpose for collecting (or sharing) the information, the categories of third parties with whom we share personal information, and specific pieces of personal information we hold about you.
• Right to Delete: You have the right to request that we delete personal information we have collected from you, subject to certain exceptions. Once we receive and confirm a verifiable deletion request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies (for example, if we must keep information to comply with a legal obligation, to complete a transaction you requested, to detect security incidents, etc.).
• Right to Opt-Out of Sale/Sharing: You have the right to opt out of the sale or certain types of sharing of your personal information. However, as noted above, Clara Fortuna does not sell personal information to third parties. We also do not share personal information for cross-context behavioral advertising. In the event our practices change, we will update this Policy and provide a straight forward method for you to exercise an opt-out.
• Right to Correct: You have the right to request that we correct any inaccurate personal information we maintain about you. If you believe the information we have is incorrect, please contact us and, upon verification, we will correct our records as necessary.
• Right to Limit Use of Sensitive Information: If we collected any sensitive personal information (as defined by law), you would have the right to limit its use and disclosure to what is necessary to perform our services or as otherwise permitted by law. Note: Clara Fortuna does not collect or process sensitive personal information (such as government IDs, financial account info, precise geolocation, or racial/ethnic origin) in the context of our services, so this right may not be applicable beyond basic contact details.
• Right to Non-Discrimination: We will never discriminate or retaliate against you for exercising any of your privacy rights. This means we will not deny you services, charge you different prices, or provide a different level of service quality solely because you exercised your rights under the CCPA.
• Exercising Your Rights: If you are a California resident (or an authorized agent acting on your behalf) and wish to exercise any of the above rights, you may submit a request to us by emailing privacy@clarafortuna.com or by contacting us as described in the Contact Us section below. Please specify which right you intend to exercise and provide enough information for us to verify your identity (for example, your name, contact information, and relationship with Clara Fortuna). We will only use the information you provide to verify your identity or authority to make the request and to fulfill your request. Once we receive a request, we will confirm receipt within 10 business days and respond as required by law(generally within 45 calendar days of receiving a verifiable request, with the possibility of a 45-day extension if necessary, of which we would notify you).If we cannot fulfill your request, we will explain the reason (for instance, if we are unable to verify your identity or if a legal exception applies).
• Utility Client Data: If you are a customer of one of our utility clients and have questions or requests regarding personal information that the utility holds about you, we recommend that you direct your inquiry to the utility company. We act as a service provider to our clients, and in many cases we do not control the data needed to fulfill certain requests (such as deletion or access to utility account records) without the involvement of the utility. However, if you mistakenly direct a CCPA request to Clara Fortuna concerning data we handle for a client, we will work in good faith with you and the client to ensure your rights are respected as required by law.
• Your Choices (Other Requests): Even if you are not a California resident, you may contact us at any time to request access to, correction of, or deletion of personal information we hold about you. We will honor such requests in our discretion and accordance with applicable law. For example, if you wish to update your contact information or request that we remove your details from our records, please contact privacy@clarafortuna.com,and we will accommodate your request whenever possible.
Our services and website are not intended for children under the age of13, and we do not direct any content specifically at children. We do not knowingly collect personal data from anyone under 13 years of age. If you are under 13, please do not submit any personal information to us.
In the event that we discover we have inadvertently collected personal information from a child under 13, we will promptly take steps to delete such information from our records. If you are a parent or guardian and believe your child has provided personal information to us without your consent, please contact us at privacy@clarafortuna.com so that we can investigate and address the issue.
Our website may contain links to external websites or services that are not operated by Clara Fortuna (for example, links to our social media profiles or resources provided by others). This Privacy Policy applies only to Clara Fortuna's Site and services. If you click a third-party link, you will be directed to a site outside our control. We are not responsible for the content or privacy practices of any third-party websites. We encourage you to review the privacy policies of any external sites you visit, as their practices may differ from ours.
We may update or revise this Privacy Policy from time to time to reflect changes in our practices, comply with new legal requirements, or for other operational reasons. When we make changes, we will post the updated Policy on this page and update the "Effective Date" at the top. If the changes are material, we may also notify you by more prominent means (such as by posting a notice on our website or contacting you directly, if appropriate).
We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. Your continued relationship with Clara Fortuna – including use of our website or services – after any update to this Policy constitutes your acceptance of the changes.
Clara Fortuna is committed to addressing any questions, concerns, or requests you may have about privacy and ethics. If you have any questions about this Privacy Policy or how we handle your data, or if you wish to exercise your privacy rights, please contact us at privacy@clarafortuna.com. You may also reach out to us by mail at: Clara Fortuna LLC, Carlsbad, CA, USA (Attn: Privacy Officer).
Additionally, we maintain an ethics hotline/contact for any concerns related to ethical conduct or compliance. If you have an ethics-related question or wish to report a concern about our business conduct, you can contact us confidentially at ethics@clarafortuna.com.We take all inquiries seriously and will respond promptly.
We value your trust and are dedicated to being a responsible steward of data. Thank you for choosing Clara Fortuna
to play in upholding this Code of Conduct and ensuring we meet our legal and ethical obligations.
• Leadership (Owners/Management): The leaders of Clara Fortuna (including the founders and any future executives) are responsible for fostering a strong culture of ethics and compliance. Management sets the “tone at the top” by exemplifying integrity in all actions and decisions. Leaders must ensure that adequate resources are devoted to compliance efforts, even in a small business setting. This includes establishing and maintaining this Code of Conduct, allocating time for training, and encouraging open discussions about ethics. Our management will also periodically assess the company’s risks and compliance needs (for example, evaluating new regulatory requirements as our services or client base expands). As we grow, leadership will consider appointing or hiring a dedicated compliance officer or creating a compliance committee to oversee and strengthen our program. For now, one of the co-founders has been designated to serve as the compliance point of contact, with ultimate accountability for compliance tasks and issues.
• Employees: Every Clara Fortuna employee, regardless of position or tenure, is expected to understand and adhere to the Code of Conduct, performing their duties ethically and incompliance with the law. Compliance is not "someone else's job" – itis part of each person's job. Employees should familiarize themselves with the contents of this Code and participate in training sessions to deepen their understanding (see Section 8, "Training"). Suppose an employee is unsure about a policy or faces an ethical dilemma. In that case, it is their responsibility to seek guidance (from a supervisor or the compliance contact)rather than guessing or ignoring the issue. Employees are also responsible for reporting any suspected misconduct or violations (per Section 6). By being vigilant and speaking up, employees help the company catch and address issues early. We expect all team members to actively support our compliance culture by encouraging each other to act with integrity and by never pressuring anyone to bend or break the rules.
• Compliance Officer/Function: Clara Fortuna has designated a compliance responsibility to a co-founder at this stage. This person’s role is to coordinate our ethics and compliance efforts–keeping the Code of Conduct up to date, ensuring training and communications are effective, serving as a confidential resource for questions or reports, and monitoring compliance with policies. The compliance point person will also track any incidents or concerns raised and report significant issues to ownership or (if in the future we have a board of directors or advisors) to that governing authority, consistent with the Federal Sentencing Guidelines' emphasis on oversight at high levels. As we grow to 10 or more employees, we anticipate further formalizing the compliance function, potentially by assigning a dedicated officer or creating written procedures for compliance tasks. Regardless of title, the person overseeing compliance has direct access to the company's leadership and the authority to recommend improvements or corrective actions needed to maintain an effective program.
• External Partners and Stakeholders: Although this Code is primarily intended for Clara Fortuna's internal use, we also expect our contractors, consultants, and any third parties acting on our behalf to conduct themselves in a manner consistent with our standards. We will make this Code (or relevant portions of it) available to those who need to know our expectations. We will abide by the vendor’s conduct requirements and ensure that our employees are informed about these standards. Upholding ethics is a shared responsibility in any partnership. Clara Fortuna's leadership will communicate with our clients and suppliers about our commitment to compliance and cooperate fully with any ethics and compliance inquiries or audits from clients.
In summary, the success of our compliance program depends on the active involvement of all personnel. By clearly defining these roles and responsibilities, Clara Fortuna aligns with the best practices for small business compliance programs and ensures accountability at every level. We all must work together to uphold the principles of this Code.
Education is a critical component of an effective ethics and compliance program. Clara Fortuna is committed to providing training and resources to ensure that all employees understand the Code of Conduct and are prepared to apply its principles in their work. We also recognize the importance of ongoing communication to keep ethics top of mind and to update the team on any changes in policies or regulations.
• Onboarding and Ongoing Training: Every new employee of Clara Fortuna will receive a copy of this Code of Conduct and training on its contents upon joining the company. The training will cover our core values, key policies, and real-life scenarios to illustrate how to handle ethical dilemmas effectively. Top management will introduce the importance of the compliance program during onboarding to set the right tone from the start. We will also conduct periodic refresher training for all employees, at least annually or more frequently as needed, to reinforce expectations and inform everyone of any updates or new compliance requirements. These sessions may include reviewing case studies, invite questions, and discuss any lessons learned from recent compliance issues (while respecting confidentiality). In a small team, training can be informal and discussion-based, but it will be treated as a vital activity, not an afterthought.
• Continuous Communication: Beyond formal training sessions, Clara Fortuna's leadership will maintain regular communication about ethics and compliance. This can be through team meetings, email bulletins, or one-on-one conversations. We will celebrate ethical behavior and highlight positive examples of our values in action, to show that integrity is recognized and valued. Important compliance information, such as reminders about data security practices or updates on relevant laws, will be shared promptly. We encourage open dialogue: employees should feel comfortable asking questions during meetings or reaching out to the compliance officer at any time. No question is "silly" when it comes to ethics; if something is unclear, we want to clarify it.
• Accessible Language and Format: We strive to make all training materials and communications easy to understand, avoiding unnecessary jargon. This Code of Conduct itself is written in clear language intended for both our staff and external stakeholders. If anyone, including those outside the company(such as clients or subcontractors), has questions about our Code, we will do our best to explain our standards and expectations. The Code will be made accessible (for instance, provided to new business partners or posted on a company intranet or website) so that it can be referenced at any time.
• Documentation and Acknowledgment: We will document that each employee has received and understood the Code of Conduct. This may involve having employees sign an acknowledgment form upon completing training or reading the Code. Maintaining records of training completion and acknowledgments is a key aspect of demonstrating our commitment to an effective compliance program, in line with federal guidelines. These records also help us track who may need refresher training or if any areas of the Code are consistently misunderstood and need more emphasis.
By investing in training and open communication, Clara Fortuna ensures that our team is equipped to make ethical decisions and comply with our obligations. An aware and educated workforce is our best defense against compliance risks. We believe that ongoing education not only helps prevent misconduct but also creates a shared sense of purpose and pride in our company’s values.
When a concern is raised or a potential violation of this Code (or any law or regulation) is identified, Clara Fortuna will respond promptly and effectively. We have procedures in place to investigate issues fairly and to resolve them in a manner that prevents future occurrences. This proactive approach aligns with the Federal Sentencing Guidelines’ emphasis on responding quickly to offenses and taking corrective action.
• Investigation Process: All reports of suspected misconduct or violations will be thoroughly investigated and taken seriously. The company will assign an appropriate person to investigate the matter; this may be the designated compliance officer, a member of management not involved in the issue, or an external expert if the situation warrants (for example, outside legal counsel for a complex legal issue). Investigations will be conducted promptly and in a confidential manner. The investigator will gather relevant facts, which may include interviewing people involved, reviewing documents or communications, and securing any evidence. Employees are expected to cooperate fully and truthfully with investigation efforts. Do not interfere with an investigation, lie, withhold information, or retaliate against anyone involved– such actions are themselves violations of this Code and potentially the law.
During the investigation, the company will determine whether it needs to take any immediate actions (for example, pausing a project if there’s a safety concern, or temporarily reassigning someone if there is an allegation of harassment) to ensure safety and integrity. We aim to be objective and impartial in our fact-finding. The outcome of the investigation will be documented, and the findings will be reviewed by appropriate leadership.
• Corrective Action and Discipline: If an investigation confirms that a violation of the Code or law occurred, Clara Fortuna will take appropriate corrective action. This can include a range of responses depending on the severity and nature of the violation. Potential disciplinary actions against employees who violated the rules include verbal or written warnings, mandatory training or coaching, suspension, demotion, or termination of employment. We will enforce our standards through well-publicized guidelines and consistent discipline, so that everyone understands that misconduct has consequences. Even if the offender’s intentions were not malicious, violations cannot be ignored. On the other hand, disciplinary decisions will consider the facts and context; we will be fair and proportional, ensuring that similar violations receive similar treatment. In addition to discipline, corrective action may involve fixing any harm caused. For example, if confidential data was improperly disclosed, we will take steps to contain the leak and notify affected parties if required. If a client’s trust is broken, we will apologize and make amends as appropriate. Clara Fortuna may also need to report certain violations to external authorities or clients. For instance, if a law was broken, we will consider self-reporting to law enforcement or regulators, which can potentially reduce penalties by demonstrating our cooperative stance (indeed, companies that self-report and have compliance programs can receive reduced fines under the Sentencing Guidelines). If the issue involves our work with a, we will inform them as needed under our vendor obligations and work with them to resolve the matter.
• Whistleblower Follow-Up: After an investigation, we will inform the reporting individual (if known) that the matter has been addressed to an appropriate extent. We might not be able to share all details for private reasons, but we want reporters to know their concerns were heard. We will also monitor the situation to ensure that no retaliation occurs against anyone who reports or participates, reinforcing our commitment to whistleblower protection.
• Continuous Improvement: Each incident(whether a confirmed violation or a near-miss) is an opportunity for Clara Fortuna to improve our controls and prevent future issues. Management and the compliance officer will evaluate whether the incident reveals any weakness in our policies, training, or internal controls. If so, we will update this Code, provide additional training, or implement new safeguards as necessary. This feedback loop is essential for maintaining an effective compliance and ethics program over time. Our goal is not only to address problems that arise, but to learn from them so we can strengthen our ethical culture.
• Conclusion: By having clear procedures for investigation and resolution, Clara Fortuna ensures that no report of misconduct falls through the cracks and that we respond to issues decisively and justly. We are committed to resolving issues in a manner that respects the rights of all parties involved, complies with applicable laws and regulations, and maintains the integrity of our business. In doing so, we maintain the confidence of our employees, clients, and partners that issues are handled properly and that our commitment to ethics is unwavering.
Clara Fortuna's leadership endorses this Code of Conduct and is to be followed by all employees and representatives of the company. We count on everyone to uphold these standards every day. By working together and holding ourselves accountable, we will continue to build an organization that is not only successful but also deserving of the trust placed in us by our partners, clients, and community. Clara Fortuna will review this Code periodically and communicate any updates to all staff. Thank you for doing your part in fostering an ethical and compliant culture at Clara Fortuna.
