At WaterSmart we give a high priority to data security and privacy. It’s important to us that you understand when and how we use your personal data, particularly on behalf of your water utility / service provider (“Water Service Provider”). This policy explains what kind of data we collect, where it comes from and how we may use it.
- WE COLLECT INFORMATION ABOUT YOU FROM YOUR WATER SERVICE PROVIDER AND DIRECTLY FROM YOU WHEN YOU USE OUR SERVICES.
“Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data that is not associated with or linked to your Personal Data. Anonymous Data does not permit the identification of individual persons. All Personal Data is kept strictly confidential and is used solely to provide authorized Services to you and/or your Water Service Provider and enhance such Services. We collect Personal Data and Anonymous Data, as described below.
(a) Personal Data We Collect about You from Your Water Service Provider. In connection with providing water use data and other services to you, your Water Service Provider collects information about how much water you are using through their metering systems. In connection with our Services, your Water Service Provider may supply us with your current and historical water use data and certain Personal Data, which may include your first and last names, the address where water use data is collected, account number, water audit data, and prior participation in water conservation programs, to provide our personalized Services and our Site to you and related Services to your Water Service Provider.
(b) Personal Data You Provide to Us. When you sign up for an account on our Site (your “Account”), we collect Personal Data from you such as your first and last names, e-mail and mailing addresses, password, and household information such as number of occupants, landscape characteristics, and water- and energy-using fixtures in your house. If you use our Site without signing up for an Account, you may elect to provide us with your email address.
(c) Personal Data From Other Sources. We may also receive Personal Data about you from: (i) third parties that provide services for us in connection with the Site or Services, (ii) third parties to whom you have voluntarily provided information, and (iii) other publicly available sources such as County parcel records, Census data and mapping services. We may add this information to the information we have already collected from you, or Your Water Service Provider.
(i) “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. Persistent Cookies can be removed by following Internet browser help file directions. We encode our Cookies so that only we can interpret the information stored in them. If you choose to disable Cookies, some areas of our Site may not work properly.
(ii)”Web beacons” are images embedded in a web page or email for the purpose of measuring and analyzing Site usage and activity. We, or our third party service providers acting on our behalf, may use Web beacons to help us analyze Site usage and improve our Services.
- HOW WE USE PERSONAL DATA, ANONYMOUS DATA AND AGGREGATE DATA
(a) In general, Personal Data you submit to us is used to process your water use data for use with our Services and on our Site and to respond to requests that you make, or to aid us in serving you better. WaterSmart uses your Personal Data in the following ways: to facilitate the creation of and secure your Account on our network; to identify you as a user in our system; to provide you with our Services, including information about your water use; to communicate with you about our Services and opportunities and tips to lower your water use; to provide improved administration of our Site and Services; to improve the quality of experience when you interact with our Site and Services; to send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created; to send you administrative e-mail notifications, such as security or support and maintenance advisories; to provide you with hardcopy or electronic newsletters, or surveys; to send upgrades and communications related to our Services; and to provide related Services to your Water Service Provider.
(b) Creation of Anonymous Data. We may create Anonymous Data records from Personal Data by excluding information (such as your name or account number) that make the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve our Site navigation. The disclosure and use of Anonymous Data is governed by our contract with your Water Service Provider.
(c) Aggregate Data. We may aggregate data about water usage in various formats such that the data becomes anonymous and cannot be identified personally with you. For instance, aggregate data could be a summary of total water usage for all residences in a certain geographic area or climate. Aggregate data does not contain personally identifiable information. The disclosure and use of aggregate data is governed by our contract with your Water Service Provider.
- YOUR PERSONAL DATA IS NOT SHARED WITHOUT YOUR PERMISSION
(a) Permission. We do not share your Personal Data without your permission. Exceptions to this general rule are below.
(b) Storage and Security. Personal Data is stored in the hosting environments of cloud service providers with best practice security certifications we consider appropriate. We provide additional information on security practices in Section 6 below.
(d) Other Disclosures. Regardless of any choices you make regarding your Personal Data (as described below), WaterSmart may disclose Personal Data if it believes in good faith that such disclosure is necessary or appropriate to comply with relevant laws or to respond to subpoenas or warrants served on WaterSmart or assist law enforcement authorities, or in any litigation involving WaterSmart.
- WE WILL NOT SELL, LEND OR GIVE YOUR PERSONAL DATA TO UNAUTHORIZED THIRD PARTIES OFFERING OTHER PRODUCTS OR SERVICES
(d) Disclosure to Your Water Service Provider. We may share your Personal Data with your Water Service Provider to, among other things (i) improve understanding of customer water usage patterns, (ii) to plan water efficiency strategies and (iii) to help you and their other customers conserve water. The privacy policies of your Water Service Provider will apply to its use and disclosure of your Personal Data.
- YOU MAY OPT OUT OF RECEIVING EMAILS AND CAN UPDATE YOUR PERSONAL INFORMATION AT ANY TIME
(b) Changes to Personal Data. You may change any of your Personal Data in your Account by editing your profile within your Account. You may request deletion of your Personal Data by us, but please note that we may be required to keep this information and not delete it in accordance with Section 3, applicable law, or our contractual obligations to third parties (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, portions of your data may remain on a backup server or media. WaterSmart keeps these backups to ensure our continued ability to provide the Services to you in the event of malfunction or damage to our primary production servers. We also reserve the right to use or disclose any aggregate data or Anonymous Data derived from or incorporating your Personal Data indefinitely if permitted by our contract with your Water Service Provider.
- WE DO OUR BEST TO KEEP YOUR DATA SECURE
WaterSmart is committed to protecting the security of your Personal Data. We use a variety of industry-standard security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. Under our information security policy we focus on tight access control to Personal Data, encryption of Personal Data in transfers, partnering with best-in-class cloud vendors for physical and environmental security, automation for change-management accuracy, human resources security to ensure all necessary controls on employees, and other security measures. We also require you to enter a password to access your Account information. Please do not disclose your Account password to unauthorized people. You are responsible for maintaining the confidentiality of your password. Despite these measures, you should know that WaterSmart cannot fully eliminate security risks associated with Personal Data and security breaches are possible.
WaterSmart Software, Inc.
Attn: Customer Service
20 California Street, Suite 200
San Francisco, CA 94111