Privacy Policy

Williams Lighting Control Services, LLC, doing business as Wilco Services ("Company," "we," "us," or "our"), respects your privacy and is committed to protecting the personal information you share with us. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website or engage our services. This policy is governed by the laws of the State of Texas.

1. Information We Collect

We may collect the following types of information:

Personal Information

• Name
• Email address
• Phone number (including mobile number, if provided)
• Company or organization name
• Job title or role
• Billing address and payment information (for invoiced engagements)
• Electronic signature data, including identity confirmation, timestamp, and IP address, when forms are signed through GoFormz or other electronic signature platforms
• Any information you voluntarily provide through our contact form or direct communications

Project & Technical Information

• Project details, scope documents, floor plans, fixture schedules, and control zone layouts provided by the client
• System credentials, including network passwords, IP addresses, VPN access information, and manufacturer platform login details, provided for the purpose of remote access or system programming
• Technical system information, including device configurations, network topology, and commissioning data
• Photographs and visual documentation of project sites and installed systems taken by Wilco Services personnel during service visits

Automatically Collected Information

• Browser type and version
• Operating system
• IP address
• Pages visited and time spent on our website
• Referring website addresses

2. How We Use Your Information

We may use the information we collect for the following purposes:

• To respond to your inquiries and provide customer support
• To provide, maintain, and improve our services
• To communicate with you about projects, services, and updates
• To deliver programming, commissioning, startup, training, and consulting services
• To perform warranty service and ongoing support for completed projects
• To prepare and deliver energy code compliance documentation
• To issue certificates of insurance or fulfill other project-specific administrative requirements
• To process invoices, change orders, and project-related agreements
• To document and archive project records for warranty and support purposes
• To use project photographs in portfolio, training, and marketing materials, subject to the terms of Section 10
• To comply with applicable laws, regulations, and legal process
• To protect our rights, privacy, safety, or property
• To analyze website usage and improve user experience

Data Minimization. Wilco Services collects only the personal and technical information that is reasonably necessary for the specific purpose for which it is collected. We do not collect personal data speculatively or for purposes beyond those described in this Privacy Policy.

Aggregated & Anonymized Data. Wilco Services may use anonymized, aggregated data — such as general statistics about project types, system categories, or commissioning outcomes — for internal analysis, service improvement, and business development. This data contains no personally identifiable information and cannot be used to identify any individual or client.

3. Disclosure of Your Information

We do not sell, trade, or rent your personal information to third parties. We may share your information in the following limited circumstances:

• Service Providers: We may share information with trusted third-party vendors who assist us in operating our website or conducting our business. Such vendors are required to protect your information and are contractually prohibited from using it for any purpose other than providing services to us. They may not sell, share, or disclose your information for their own marketing or commercial purposes.
• Legal Requirements: We may disclose your information if required to do so by law, court order, or in response to valid requests by public authorities, including to meet national security or law enforcement requirements.
• Protection of Rights: We may disclose information where we believe disclosure is necessary to protect the rights, property, or safety of Wilco Services, our clients, or others — including to enforce our Terms and Conditions or to exercise our lien rights under Texas law.
• Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will provide notice before your personal information is transferred and becomes subject to a different privacy policy.

4. SMS and Mobile Messaging

If you provide your mobile phone number to us — for example, through our contact form, project intake process, or direct communications — you may receive text messages (SMS) from us related to your inquiry, project updates, scheduling, or service communications.

Message and Data Rates

Message and data rates may apply. Standard carrier message and data rates may apply to any SMS communications you receive from us. These charges are assessed by your mobile carrier and are beyond our control.

Messaging Frequency

Message frequency varies. We send text messages only as necessary in connection with your inquiries or active projects. We do not operate a recurring promotional SMS program.

Opt-Out

You may opt out of receiving text messages from us at any time by replying STOP to any message you receive. You may also contact us directly at [email protected] to request removal from our messaging list. After opting out, you may receive one final confirmation message. For help, reply HELP to any message or contact us via email.

Non-Sharing of Mobile Numbers

No mobile information will be shared with third parties, affiliates, or lead generators for marketing or promotional purposes at any time. Mobile phone numbers and mobile opt-in data collected by Wilco Services are used solely for direct communications related to your project or service request and will never be sold or disclosed to any third party for marketing, advertising, or lead generation purposes.

For the full terms governing SMS communications, including opt-in and opt-out procedures, please see Section 5 of our Terms and Conditions.

Employee Messaging (WLCS)

If you are an employee of Williams Lighting Control Services, LLC ("WLCS"), your employment with WLCS constitutes your consent (opt-in) to receive text messages and other electronic communications from WLCS that are related to business operations. These messages may include, but are not limited to, scheduling and dispatch updates, jobsite coordination, safety communications, and weather alerts.

Message frequency may vary. Standard message and data rates may apply depending on your mobile carrier and plan.

Employee mobile information will not be shared with third parties, affiliates, or lead generators for marketing or promotional purposes at any time.

5. Data Security

We implement reasonable administrative, technical, and physical security measures to protect your personal information from unauthorized access, use, alteration, or destruction. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

System Credentials

When clients provide system credentials — including network passwords, IP addresses, VPN access details, or manufacturer platform logins — for the purpose of remote access or programming services, Wilco Services commits to the following:

• System credentials are used solely for the performance of the agreed-upon services and are not shared with unauthorized third parties
• Credentials are not retained beyond the active period of the engagement unless the client has provided written authorization for ongoing remote access
• Upon project completion or client request, Wilco Services will confirm deletion of stored credentials
• Wilco Services will promptly notify the client in writing if it becomes aware of any suspected unauthorized access to or disclosure of system credentials

Clients are strongly encouraged to change system passwords and revoke remote access credentials promptly after project completion. Wilco Services is not responsible for security incidents arising from the client's failure to rotate credentials after services conclude.

6. Texas Privacy Rights

Under the Texas Data Privacy and Security Act (TDPSA), effective July 1, 2024, Texas residents have specific rights regarding their personal data, including:

• Right to Access: You have the right to confirm whether we are processing your personal data and to access that data.
• Right to Correction: You have the right to correct inaccuracies in your personal data. Wilco Services is committed to maintaining reasonably accurate records and will promptly correct confirmed inaccuracies upon written request.
• Right to Deletion: You have the right to request deletion of your personal data, subject to exceptions required by law or necessary for legitimate business purposes such as warranty obligations or legal compliance.
• Right to Data Portability: You have the right to obtain a copy of your personal data in a portable and readily usable format.
• Right to Opt Out: You have the right to opt out of the processing of your personal data for purposes of targeted advertising, sale of personal data, or profiling. Wilco Services does not sell personal data or use it for targeted advertising or profiling.

How to Submit a Rights Request

To exercise any of the rights above, submit a written request to [email protected] with the subject line "Privacy Rights Request." Your request should include:

• Your full name and the email address associated with your account or project
• The specific right you are exercising (access, correction, deletion, portability, or opt-out)
• For correction requests: the specific data to be corrected and the correct information
• For deletion requests: the category or description of data to be deleted

We will verify your identity before processing your request. Verification may include confirming your email address, project affiliation, or other identifying information on file. We will respond within 45 days as required by the TDPSA. If we need additional time, we will notify you within the initial 45-day period and may extend the response period by an additional 45 days.

Appeals

If we decline to act on your request, we will notify you of the reason within the applicable response period. You may appeal our decision by submitting a written appeal to [email protected] with the subject line "Privacy Rights Appeal." We will respond to your appeal within 60 days. If your appeal is denied, you may contact the Texas Attorney General's office to submit a complaint.

7. Cookies, Tracking Technologies & Do Not Track

Our website may use cookies and similar tracking technologies to enhance your browsing experience. You can set your browser to refuse all or some cookies, or to alert you when cookies are being sent. If you disable cookies, some features of our website may not function properly.

Do Not Track & Global Privacy Control (GPC). Some browsers and browser extensions transmit "Do Not Track" (DNT) signals or Global Privacy Control (GPC) signals indicating a preference that websites not track browsing activity. In accordance with the Texas Data Privacy and Security Act (TDPSA), Wilco Services honors Global Privacy Control signals as a valid opt-out of the sale of personal data and targeted advertising. Because Wilco Services does not sell personal data or engage in targeted advertising, honoring these signals has no practical effect on our current data practices — but we acknowledge and respect them as a matter of compliance and transparency. We do not currently respond to browser-level DNT signals that fall outside the GPC framework, as no uniform standard has been adopted for those signals.

8. GoFormz — Change Orders, Programming Requests & Startup Service FSRs

Wilco Services uses GoFormz, a third-party digital forms platform, to deliver, collect, and process operational documents. Current forms include, but are not limited to:

• New Account Form
• Change Order Form
• Programming Request Form
• Startup Service Field Service Report (FSR)
• Any other forms delivered by Wilco Services through the GoFormz platform

Information Collected Through These Forms

These forms may collect information such as your name, company, email address, project details, and any other information you provide in the course of completing the form. This information is used solely for the operational purpose of the specific form transaction (e.g., processing a change order, scheduling a programming request, or documenting a startup service).

Automated Email Notifications

GoFormz automatically sends transactional email notifications to email addresses associated with a submitted form. These notifications are limited to confirmation of receipt, signature requests, or delivery of a completed form copy. They are triggered solely by the specific form transaction and are not part of any marketing or recurring email program.

No Marketing Emails — No Recurring Emails

Wilco Services does not use GoFormz to send marketing, promotional, or recurring emails. Your email address collected through a GoFormz form is not added to any marketing list, newsletter, or subscription program.

Data Storage

Information submitted through GoFormz is not stored by Wilco Services in any separate marketing or analytics database. It is retained only as necessary for the operational record associated with your project or service transaction. GoFormz is an independent third-party service; their data handling practices are governed by the GoFormz Privacy Policy.

9. Third-Party Platforms Used in Service Delivery

In addition to GoFormz (described in Section 8), Wilco Services may use other third-party software platforms, cloud services, and digital tools in the course of delivering services. These may include manufacturer programming platforms, remote access tools, network diagnostic utilities, and electronic signature platforms. Each of these is owned and operated by an independent third party.

Wilco Services does not control the data practices of these third-party platforms. Information processed through these tools — such as system configuration data, session logs, or access records — may be subject to the respective platform's privacy policy. Wilco Services is not responsible for any data collection, retention, or disclosure practices of third-party platforms, and clients are encouraged to review the privacy policies of any third-party tools used in connection with their project.

Wilco Services will not use third-party platforms to share personal client information for marketing, advertising, or any purpose unrelated to the delivery of services.

10. Project Records, Documentation & Photography

Wilco Services retains copies of project records for warranty service, ongoing support, and internal reference purposes. Retained records may include as-programmed documentation, commissioning reports, device and zone schedules, energy code compliance documentation, field service reports, and related technical files. These records are used solely for the purpose of supporting the specific system they relate to and are not shared with third parties except as required to perform warranty or support services.

Wilco Services may photograph completed project work for internal records, portfolio use, training materials, and marketing purposes. Photographs will not include personally identifiable information about facility occupants or end users. Client or facility names will not be associated with photographs in public marketing materials without the client's prior written approval. Clients who do not wish to have project work photographed must notify Wilco Services in writing before services begin.

11. Testimonials

If you provide a testimonial, review, or endorsement of Wilco Services, we may use your words — along with your name, title, and company name, as you prefer — in marketing materials, on our website, and across social media and professional profiles. We will not alter the meaning of any testimonial. You may withdraw consent to use your testimonial at any time by contacting us in writing, and we will remove it from future publications within a commercially reasonable timeframe. Previously published materials containing your testimonial are not retroactively recalled.

12. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of those websites. We encourage you to review the privacy policies of any third-party sites you visit.

13. Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child under 18, we will take steps to delete that information promptly.

14. Governing Law, Jurisdiction & International Visitors

This Privacy Policy shall be governed by and construed in accordance with the laws of the State of Texas, without regard to its conflict of law provisions. Any disputes arising under this Privacy Policy shall be resolved exclusively in the state or federal courts located in Harris County, Texas.

International Visitors. This Privacy Policy is designed for residents of the United States. Wilco Services is based in Texas and operates under U.S. federal and Texas state law. If you are located outside the United States and choose to provide personal information to us, please be aware that your information will be transferred to, stored, and processed in the United States, where privacy laws may differ from those in your jurisdiction. By providing your information, you consent to this transfer and processing. Wilco Services does not represent that this Privacy Policy complies with the legal requirements of any jurisdiction outside the United States, including the European Union General Data Protection Regulation (GDPR) or similar frameworks.

15. Changes to This Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time. Any changes will be posted on this page with an updated "Last updated" date. Your continued use of our website after any changes constitutes your acceptance of the revised policy.

16. Data Retention

Wilco Services retains personal and project information only for as long as necessary to fulfill the purposes for which it was collected, to provide ongoing warranty and support services, or as required by applicable law. The following general retention guidelines apply:

• System Credentials: Retained only during the active engagement. Deleted upon project completion or upon client request, whichever occurs first, unless the client has authorized ongoing remote access in writing.
• Project Records & Technical Documentation: Retained for the duration of the applicable warranty period plus a reasonable archive period (generally seven (7) years) to support warranty claims, legal compliance, and historical reference. These records may include as-programmed files, commissioning reports, field service reports, and energy code compliance documentation.
• GoFormz Form Records: Retained as part of the operational record of the associated project or transaction, consistent with the project records retention period above.
• Contact Form Inquiries (Non-Project): Personal information submitted through our website contact form that does not result in an active project engagement is retained for up to two (2) years and then deleted or anonymized.
• Billing & Invoice Records: Retained for a minimum of seven (7) years in accordance with standard business and tax record-keeping requirements.
• Project Photography: Retained indefinitely for portfolio and internal reference purposes unless the client has requested removal in writing, in which case photographs will be removed from active use within a commercially reasonable timeframe.
• Website Analytics Data (Automatically Collected): Retained for up to twenty-four (24) months and then aggregated or deleted.

When personal data is no longer needed for its stated purpose and no legal retention obligation applies, Wilco Services will delete or anonymize it in a secure manner. You may request early deletion of your data by submitting a written request as described in Section 6.

17. Data Breach Notification

In the event of a data breach involving personal information that Wilco Services reasonably believes has been acquired by an unauthorized person, Wilco Services will take the following steps:

• Containment: We will promptly take reasonable steps to identify, contain, and remediate the breach upon discovery.
• Assessment: We will assess the nature and scope of the breach, including what categories of personal information were affected and how many individuals may be impacted.
• Notification to Affected Individuals: In accordance with the Texas Identity Theft Enforcement and Protection Act (Tex. Bus. & Com. Code § 521.053), we will notify affected Texas residents as expeditiously as reasonably possible following discovery of the breach. Notification will be provided via the email address on file for the affected individual, or by substitute notice if contact information is unavailable or the cost of individual notice is prohibitive.
• Regulatory Notification: If required by applicable law, we will notify the Texas Attorney General's office or other regulatory authorities within the timeframes prescribed by law.

Breach notifications will include, to the extent known at the time of notice: a description of the incident, the categories and approximate number of records affected, the steps Wilco Services is taking in response, and contact information for questions. We will supplement the initial notice as additional information becomes available.

If you suspect unauthorized access to your personal information in connection with a Wilco Services engagement, please contact us immediately at [email protected].

18. Employee & Personnel Privacy

Personal information collected from employees, subcontractors, and job applicants of Williams Lighting Control Services, LLC is handled separately from client data and is subject to applicable employment and labor laws. This Privacy Policy governs client and website visitor data; employee data practices are addressed through separate employment agreements and internal policies.

Certain project sites may require background checks, security clearances, or access badging for Wilco Services personnel (see Terms and Conditions, Section 39). Personal information submitted in connection with background checks or security clearance processes — such as name, date of birth, and identification documents — is handled by the applicable background screening provider and/or the facility owner, and is subject to their respective privacy practices. Wilco Services does not retain background check results beyond what is required for site access compliance, and such information is not used for any purpose other than satisfying the access requirements of the specific project site.

19. Contact Us

If you have questions or concerns about this Privacy Policy or our data practices, please contact us at: