Privacy Policy

Last Updated: January 1, 2023
Effective Date: January 1, 2023
Information for California residents

Privacy Commitment

Ƶ Company (“Ƶ” or “we”) recognizes that our customers care how their personal information is collected, used, shared, and protected. We are committed to protecting the privacy of our customers. This Privacy Policy describes the information we collect about you, why we collect it, and what we do with it. This Privacy Policy applies to information obtained through your use of (our “Website”), Ƶ’s Mobile App (the “Mobile App”) and information that you provide to us electronically, telephonically, through postal mail correspondence, or in person.

Scope of Policy

Please read this Privacy Policy carefully to understand Ƶ’s policies and practices regarding your information. If you do not agree with these policies and practices, you may choose not to use our Website or Mobile App, participate in voluntary programs, or interact with us on social media to limit the amount of information we receive about you. However, Ƶ requires your information to identify and contact you, verify your identity, bill for services, collect payment and for other related purposes necessary to provide you with electric services. We use this information as described in this Privacy Policy.

By accessing the Website, using the Mobile App or by receiving electric service from us, you consent to this Privacy Policy and to the collection and use of your information by Ƶ as specified herein. This Privacy Policy is subject to the Ƶ Terms of Use, which take precedence over any conflicting terms contained herein. Except as otherwise provided in the Terms of Use, this Privacy Policy is the entire privacy policy for the Website and the Mobile App and supersedes any prior communication on this topic.

Information We Collect – Voluntarily Provided by You

The primary reason Ƶ collects and maintains customer information is to provide services to our customers, offer additional services that may be of interest to customers like you, and to help you get the most out of our services. We obtain the following categories of information directly from you when you voluntarily provide it to us.

  • Personal Information or Identifiers.
    This category refers to information we gather about our customers that can be used to identify or contact an individual person, such as your name, e-mail address, postal address, telephone number, Social Security Number, driver’s license number, and Ƶ account number. You provide this information to establish your Ƶ account, participate in our programs, and log in to “Ƶ” on our Website or Mobile App.  We also receive this information when you fill out and submit forms to us, such as when you request information from us, apply for incentives through our programs, or enter into a promotion sponsored by us. We use or disclose this information to fulfill the purpose for which you provided it to us, to provide our services, and to educate you about our programs, energy efficiency and electrical safety.
  • Personal Information does not include information that is:
    • publicly available from government records and widely distributed media such a publicly accessible website, phone book, or online directory,
    • collected by any non-Ƶ party that may link to or be accessible from the Ƶ Website or Mobile App or otherwise collected directly by such third-party, and
    • de-identified or aggregated customer information that cannot link to an individual or household.
  • Transactional Information.This information refers to your signature on contracts you enter into with us, and any financial information that you provide directly to us, such as your bank account number or credit card information to process payment on your account. This information is voluntarily provided by you to make payment on your Ƶ account, participate in our programs, or apply for incentives.

Managing Your Personal Information

If you do not want to provide your information to us on the Website or Mobile App, you may take advantage of the publicly available content without setting up “Ƶ” or filling out any forms or information fields, however, the automatic data collection technologies may still collect the information described below.

If you believe any of the information that we collect or maintain about you is incorrect, please contact us or update the information in “Ƶ.”

Information We Collect – Indirectly from You

In addition to collecting information directly from a customer, Ƶ collects information indirectly through a variety of sources. These sources and further information as to each is detailed below.

  • Internet Activity Information.
    We collect data on our Website and Mobile App through the use of automatic data collection technologies such as cookies (small data files stored on your computer by your web browser upon visiting a website or placed on your smartphone or device), web beacons (small files that provide Website and Mobile App statistics such as how many people have visited a particular web page) and similar technologies. When you access the Website or Mobile App, Ƶ’s web servers automatically record certain data, including, but not limited to, your Internet service provider, IP address (which may identify your general geographic location or company), domain name, browser type, device type, device ID, operating system and the times and dates of your visits to our Website or use of the Mobile App. Cookies are important for the proper functioning of websites and mobile applications and enable Ƶ’s systems to remember log-in details, provide secure log-in, collect statistics to optimize the functionality of the Website and Mobile App and provide services tailored to your interests. Although you may set your browser to block all cookies, including Ƶ’s, we recommend that you leave cookies turned on to take full advantage of all the Website’s and Mobile App’s features.
  • Energy Usage Information
    Ƶ collects information about your energy usage obtained through our metering systems, including that produced by photovoltaic equipment on your property. When your energy usage information is combined with information that can identify you and/or your household residence or business, Ƶ uses that information to provide electric service, such as generating your bill, and providing additional services and programs as may be required or approved by the Arizona Corporation Commission.
  • Voice Recordings
    We use an automated “Interactive Voice Response” system to help us interact with customers who call us. This system helps us to respond promptly to customer calls by gathering the caller’s required information and routing calls to the next-available customer service representative.

Use and Disclosure of Customer Information

It is Ƶ’s general practice to treat your personal information as confidential and use it in a limited number of ways. When you provide information on the Website, through the Mobile App, over the phone, or in person, Ƶ uses that information consistent with the manner intended when you provided it. We may also use or disclose your personal information for one or more of the following purposes:

  • to establish and maintain your account and provide requested services,
  • to inform you about new rates, products and services offered by or in connection with Ƶ,
  • to improve our customer service and the services and programs we provide to you,
  • to educate you about electrical safety and energy efficiency,
  • to monitor and enhance our relationship with you,
  • to respond to inquiries, including to investigate and address your concerns,
  • for billing, collection, and credit risk reduction purposes, including notifying credit reporting agencies and collection agencies as needed to evaluate your credit or if your account is assigned for collection,
  • for identity verification purposes,
  • to assist in fraud protection and compliance with cyber security laws,
  • to mitigate the risk of identity theft,
  • to address an emergency or imminent threat to life or property,
  • to enforce and apply our own Terms of Use,
  • to meet regulatory requirements and applicable laws,
  • to provide you with access to certain features on the Website and Mobile App,
  • to notify you when Mobile App updates are available or significant changes have been made to our Website,
  • to maintain the safety, security, integrity and functionality of our Website and Mobile App,
  • to allow you to participate in Ƶ contests and promotions,
  • to further Ƶ’s business objectives consistent with the provision of safe and reliable electric service and operation of Ƶ’s electrical system or grid,
  • as requested by the Arizona Corporation Commission and staff when legally entitled to such information,
  • in the manner described to you when collecting your information,
  • to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations,
  • to comply with a legal process, such as a warrant or subpoena, and
  • to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets, in which personal information held by us about our customers is among the assets transferred.

We may use your information for any other purpose after obtaining your consent for such use.

Ƶ will not collect additional categories of information or use the information we collect about you for materially different, unrelated, or incompatible purposes from those set forth above without providing you notice.

No Sale of Customer Information

Ƶ does not provide customer information to third parties for their advertising purposes or for other purposes unrelated to Ƶ’s objectives listed above.

Ƶ does not provide or “sell” personal information about Ƶ customers for any monetary value.

Sharing Customer Information

Ƶ discloses your information to specific non-affiliated third parties who are providing services for your benefit on behalf of or jointly with Ƶ (“Service Providers”). These services include, but are not limited to, payment processing services, assisting us in providing energy efficiency programs or as otherwise described in the “Use and Disclosure of Customer Information” section above. In such situations, Ƶ limits the amount and type of information provided to that reasonably necessary to accomplish the purpose for which it was disclosed. We include language in our contracts with Service Providers designed to protect the privacy of your information and limit its use solely to the purpose for which it was provided.

Except as otherwise expressly stated in this Privacy Policy, Ƶ does not intentionally disclose information to non-Ƶ entities unless you authorize such disclosure; we believe disclosure is required to comply with laws, regulations, legal processes, or regulatory requests; or disclosure is necessary to protect the rights, property, health and safety of Ƶ, our customers, employees or others.

Retention and Destruction of Customer Information

Subject to limits imposed by applicable law, Ƶ retains information as long as your account is active and for such additional time as we believe such information is required or will be useful to fulfill a business purpose, legal requirement or law enforcement need. Ƶ reserves the right to remove any such information from its records. Ƶ uses secure disposal methods when information is no longer needed.


The security of your information is important to us. We have implemented and maintain reasonable administrative, electronic, and procedural safeguards designed to protect your information from accidental loss, and from unauthorized access, use, alteration, and disclosure. Although Ƶ believes these procedures are adequate, no method of storing or transmitting information over the Internet or via the Mobile App, including email communications, is completely secure. Accordingly, Ƶ cannot guarantee the security of your personal information transmitted to or through our Website and Mobile App and transmission of information is at your own risk. If you do not want Ƶ to know any particular information, do not include it in anything submitted to the Website or Mobile App.

The safety and security of your information also depends on you. In using certain services offered on our Website and Mobile App, you may be assigned or choose a user ID and may choose a password. You are solely responsible for maintaining the confidentiality of your user ID and password and are responsible for all activities that occur under your user ID and password. We suggest that you do not share your password with anyone. You agree to notify Ƶ immediately of any unauthorized use of your user ID, password or information, or any other breach of security regarding the Website and Mobile App of which you are aware. Ƶ will not be liable for any loss arising from your failure to comply with these security requirements and you agree to hold Ƶ harmless from any and all losses that arise from any such failure to comply.

Linked Websites

The Website and Mobile App contain links to third-party sites, including social media sites. Your use of those sites may result in the collection or sharing of your information or collect data about your online activities. Our Privacy Policy does not cover any information you provide to or that is collected by a third-party site. Ƶ does not control third-party sites and is not responsible for any information that may be gathered through a linked website. Although Ƶ has taken precautions to ensure that linked websites follow a similar privacy policy, Ƶ cannot guarantee third-party policies or practices. We urge you to review the individual policies of each website you visit. In no event will Ƶ be responsible for any third-party website policies or actions.

Changes to Our Privacy Policy

Ƶ is continuously working to improve its Privacy Policy to remain in compliance with evolving laws. Accordingly, Ƶ reserves the right, in its sole discretion, to modify the Privacy Policy from time to time. Any such change will be effective upon the posting of the revised Privacy Policy at the Website and Mobile App and Ƶ will notify you by revising the “Last Updated“ date on the top of the Privacy Policy. If we make material changes to how we treat your information, we may choose to notify you by e-mail. You are responsible for ensuring that we have a valid e-mail address for you. By continuing to use the Website and Mobile App or continuing to receive service from us after the posting of any such changes, you accept and agree to the Privacy Policy as modified. For your convenience, you may wish to print out this Privacy Policy for your records.

E-mail Marketing

Ƶ enables you to opt out of marketing communications by using the “unsubscribe” link included in such emails. However, non-marketing communications are not subject to a general opt-out and may contain important information regarding your Ƶ account, energy efficiency and electrical safety.

Compliance with Laws

Ƶ will comply with applicable federal and state laws regarding its collection and use of your information and will limit disclosures accordingly.

Children’s Privacy

We believe in the importance of protecting children’s online privacy. Our Website and Mobile App are not intended for use by children under 13 years of age. Ƶ does not knowingly collect, nor do we desire to collect, personal information from children under the age of 13. If you believe we may have received personal information from or about a child under 13 without verification of parental consent, please notify us so that we may immediately delete that information. For more information about the Children’s Online Privacy Protection Act, visit the FTC’s web site at .

Contact Us

If you have questions or comments regarding our Privacy Policy, please contact us by sending an email to or writing a letter to:

Privacy Matters
c/o Ƶ
Attn: Legal Department
PO Box 711
Tucson, AZ 85702-0711

You can also call us at 1-833-455-0259.

Supplemental Privacy Notice for California Residents

Effective Date: January 1, 2020
Last Updated: January 1, 2023

ճ󾱲PrivacyNotice for California Residentssupplements the information contained in our Privacy Policy and applies solely to our customers who are residents of the State of California (“you”). We adopt this notice to comply with the California ConsumerPrivacyAct of 2018 as amended by the California Privacy Rights Act of 2020 (together, the “CCPA”).

Personal Information Definition

Under the CCPA, “personal information” is information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device. Personal information does not include publicly available information from government records, de-identified or aggregated consumer information, and information excluded by law from the definition of personal information, such as, but not limited to, health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA).

Categories of Personal Information

As more specifically described in our Privacy Policy, depending on your interactions with us, we may have collected personal information from you during the last twelve months related to the following categories. The descriptions below detail the personal information generally collected from customers who interact with us in a variety of ways, therefore, the personal information we have about you may be more limited.

Category Examples Collected
1.Գپھ. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security Number, driver’s license number, passport number, or other similar identifiers. Some Identifies are also considered Sensitive Information as detailed in Category 12 below.

See Information We Collect – Voluntarily Provided By You.

2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

See Information We Collect – Voluntarily Provided By You.

3. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

*Ƶ collects customer birth date and information about medical devices in your home that require electricity for our Lifeline Program.

Yes, in part.*
4. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Yes
5. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

**Ƶ keeps records of any threatening behavior exhibited by customers to ensure the safety of our employees.

Yes, in part.**
6. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

See Information We Collect – Indirectly from You.

7. Geolocation data. Physical location or movements. No
8. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information.

Ƶ records customer calls as described in the section titled “Information We Collect – Indirectly from You.”

9. Professional or employment-related information. Current or past job history or performance evaluations. Yes, with respect to employees only
10. Non-public education information (per the Family Educational Rights andPrivacyAct (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. Yes, with respect to employees only
11. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

See Category 5 about the type of behavioral information we collect.

12. Sensitive Personal Information Categories. Information specifying medical or health conditions, racial or ethnic origin, precise geolocation, political opinions, religious or philosophical beliefs, trade union membership, genetic data or information specifying the sex life or sexual orientation of an individual. Identifiers such as a Social Security Number, driver’s license, state identification card or passport number are also in this category.

*** Ƶ collects information about medical devices in your home that require electricity for our Lifeline Program, but does not collect information related to medical/health conditions. Ƶ does not collect other Sensitive Personal Information, except for Identifiers set forth in Category 1 above.

Yes, in part***


Limited Use of Sensitive Personal Information

Ƶ limits the use of Sensitive Personal Information of customers to that which is essential for providing you with services, verifying your identity, and collecting payment. We do not use Sensitive Personal information for marketing or analytics purposes.


Subject to limits imposed by applicable law, Ƶ retains information as long as your account is active and for such additional time as we believe such information is required or will be useful to fulfill a business purpose, legal requirement or law enforcement need. Ƶ uses secure disposal methods when information is no longer needed.Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the purposes listed in theUse and Disclosure of Customer Informationsection above and for an authorized business purpose under the CCPA.

Sharing of Personal Information

We may disclose your personal information to a Service Provider for a business purpose as detailed above in theSharing Customer Informationsection. We share your personal information with the following categories of third parties:


Categories of Third Parties Categories of Information
Service providers 1.) Identifiers, including Ƶ account number

2.) California Customer Records personal information categories

4.) Commercial information related to the services you wish to receive

Data analytics providers or internet cookie data recipients


6.) Internet or other similar network activity. We do not provide this information directly, but it is collected through your use of the Website and Mobile App.
Your Family and Friends 1.) Identifiers. As part of Ƶ’s Safety Net Program, a customer can designate another person to receive a copy of their bill to help the customer remember to pay it on time. In such case, the customer may provide us with your name, address, or email address so that you can receive a duplicate copy of their bill.

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. We have tried to ensure that our Privacy Policy addresses much of this information, so please read it carefully.

Access to Personal Information

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. To protect your privacy, we must use your personal information to verify your request and we will only process your request after completing such verification process.

Once we have verified your request, we will inform you:

  1. The categories of personal information we collected about you.
  2. The categories of sources for the personal information we collected about you.
  3. Our business or commercial purpose for collecting the personal information.
  4. The categories of third parties with whom we share the personal information.
  5. The specific pieces of personal information we collected about you.
  6. If we disclose your personal information for a business purpose, the associated personal information categories.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions under the CCPA.

Once we have verified your request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception under the CCPA applies.

Specifically, in addition to any other applicable exception under the CCPA, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. Complete the transaction for which we collected the personal information, provide service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  5. Enable solely internal uses that are reasonably aligned with customer expectations based on your relationship with us.
  6. Comply with a legal obligation.

Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Submitting a Verifiable Request

If you would like to exercise the rights detailed above, please submit a verifiable request to us by either:

Only you, or someone legally authorized to act on your behalf, may make a verifiable request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable request twice within a 12-month period.

The verifiable request must:

  • Provide sufficient information that allows us to verify you are the person about whom we collected personal information or an authorized representative of that person.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
  • Include verification of your status as a California resident.

We will not be able to respond to your request if we cannot verify your identity or authority to make the request and confirm the personal information relates to you or someone who has provided you with the legal authority to make the request.

We will only use personal information provided in a verifiable request to verify the requestor’s identity or authority to make the request.

Response Timing

We will respond to a verifiable request within forty-five (45) days of its receipt, unless we require more time to complete your request. We will inform you of the reason for any extension period in writing.

Our response to your request will explain the reasons we cannot comply with a request, if applicable.

We will not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine your request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Right to Correct

Under the CCPA, you have certain rights to correct your personal information. If you believe we have inaccurate personal information about you, please modify your information under “Ƶ” or contact us at 520-623-7711 to update your information. We must verify your identity or your delegate’s authority to make the request on your behalf before we can update your information.


We do not and will not discriminate against you for exercising any of your CCPA rights.

No Sale of Minor Personal Information

As noted throughout this document, we do not sell customer information. As such, we do not have any actual knowledge of any sale by Ƶ of personal information of consumers under the age of 16.

Do Not Track Signals

California law requires us to inform you how we respond to web browser Do Not Track (“DNT”) signals. With no industry or legal standards on how to recognize and honor DNT signals, Ƶ does not currently respond to them. When standards become available, Ƶ will address DNT signals.