Effective Date: 01/01/2020
Golden State Water obtains personal information about you from various sources in order to provide our Services and manage our Site. “You” may be a California resident (“consumer”); a Golden State Water customer or potential customer; a Site visitor; or a Business Partner or an individual or organization inquiring about our programs, conservation reports, complaints, employment applications, or the like, as provided for on our Site. “Business Partners” may be third-party companies, such as suppliers, or affiliates that have contracted with Golden State Water to deliver various products and services on their behalf.
2. Personal Information We Collect
a) Information You Provide to Us
The personal information that you provide directly to us through our Services and Sites will be apparent from the context in which you provide the data. This information includes but is not limited to:
- The information you provide when you register for a MyGSWater account, such as your full name, account number, company name (if applicable), email address, and account login credentials.
- Information you provide when you start water utility service or submit any other service request on our Site, such as your full name, address, home phone number, mobile phone number, email address, account ID, and anything else you tell us or submit in your request. Depending on the type of request, we may also collect your government-issued ID number, Social Security number, consulate number, federal tax ID number, service address, cross streets, and/or account billing information.
- Billing and payment information you use to pay your water utility bill, such as your bank account information and/or credit or debit card information to facilitate online and automatic bill payments; credit history; email address; and/or mailing address if different from the service address.
- Information you provide to determine eligibility for or to participate in applicable programs or services, such as your household income, the number of individuals residing in your home, or your enrollment in other governmental programs.
- Information collected by our metering systems and other equipment when you use water.
When you respond to Golden State Water emails, we collect your email address, name, and any other information you choose to include in the body of your email or responses. If you contact us by phone, we will collect the phone number you use to call us and additional information in order to verify your identity.
If you are a customer, when you make payments or conduct transactions through our Sites, we will receive your transaction information. The information that we collect will include payment method information (such as credit or debit card number, or bank account information), payment amount, date of payment, and payment method. Different payment methods we offer may require the collection of different categories of information. The payment method information that we collect will depend on the payment method that you choose to use from our list of payment methods we offer. When you make a transaction or enroll in automatic payments, we may also receive your full name, account number, email address, billing or shipping address, and in some cases your answers to our security questions to authenticate you.
When you apply to participate in one of our utility programs, we may receive your full name and contact information, service and mailing address, account number, and telephone number. We will collect different categories of information depending on the program and applicable legal requirements for that program. For example, if you apply for our Assistance for Low-Income Customers or Supplier Diversity Program, we may collect information about your ethnicity, financial statements, and other information about you or your organization required to process your application.
When you contact us to report a water waste or submit a conservation request through our Site, we may collect your full name and contact information, account number, and other information needed to process your inquiry. We may also receive photos of you that are submitted by you or others to be featured on our Water Efficient Garden Community Page.
You may also choose to submit information to us via other methods, including (i) when you sign up for the Golden State e-Newsletter; (ii) when you submit questions to us via our Site; (iii) in response to marketing or other communications; (iv) through social media or online forums; (v) through participation in an offer, program, or promotion; (vi) in connection with an actual or potential business relationship with us; (vii) when you submit a media inquiry; or (viii) when you apply for employment with Golden State Water.
b) Personal Information We Collect Automatically on Our Sites
- Browser and device data, such as IP address, device type, operating system name and version number, internet browser type, screen resolution, device manufacturer and model, language, plug-ins, and add-ons on the Sites you are visiting;
- Usage data, such as time spent on the Sites, pages visited, links clicked, language preferences, and the pages that led or referred you to our Sites.
Your browser or device may include “Do Not Track” functionality. At this time, the Site does not respond to browser “Do Not Track” signals.
c) Information From Third-Party Sources
We may also obtain certain information about you from third-party sources, including service providers, payment portals you opt to use outside of those authorized by us, credit agencies, Business Partners, and other third parties to help us provide and improve the Services. We may supplement the information that you provide with information that we obtain from other sources, including both online and offline data providers. Such supplemental information may include contact information, such as your email address, demographic data, or other relevant information.
d) Anonymized Information
3. How We Use Personal Information
We may use the information we collect from you to provide water utility services to you, facilitate business relationships, comply with our regulatory and other legal obligations, and pursue our business interests. We generally use the information we collect for the following purposes:
- Provide water utility services to you, including to enter into a contract for services, process payments, fulfill orders, respond to inquiries, send service communications, and provide customer support.
- Operate and maintain safe, secure, and reliable water utility services and equipment to comply with Golden State Water’s legal obligations as a regulated public utility in California.
- Interact with you, including to send you direct marketing communications if you consented to us doing so.
- Promote, analyze, modify, and improve our Services and programs, systems, and tools, and develop new services and programs.
- Manage, operate, and improve the performance of our Sites and Services by understanding their effectiveness and optimizing our digital assets.
- Enable third parties, service providers, suppliers, vendors, and contractors that provide water-related services or equipment on our behalf and Business Partners to help us operate and improve our business.
- Notify credit-reporting agencies and collection agencies to evaluate your credit or if your account is assigned for collection.
- Assist emergency responders in situations of threat to life or property.
- Comply with a California Public Utilities Commission (CPUC) request or order, or comply with a request by courts, government agencies, law enforcement, or other government authorities.
- Comply with a valid warrant, subpoena, or court order, or assert or defend legal claims.
- Monitor, prevent, and detect activities that may violate our policies or be fraudulent or illegal, and protect against other threats to the safety and security of Golden State Water, you, or others.
If we need to use your personal information in other ways, we will provide specific notice at the time of collection and obtain your consent where required by applicable law.
4. How We Share Personal Information
Golden State Water does not sell or rent personal information to marketers or other unaffiliated third parties. We share your personal information with trusted entities, as outlined below.
a) Service Providers
We share personal information with our service providers that perform certain services on our behalf, such as web hosting, data analysis, Site operations and optimization, information technology and related infrastructure, customer service, email delivery, marketing automation, payment processing, content management, and auditing. We authorize such service providers to use or disclose the personal information only as necessary to perform services on our behalf or comply with legal requirements. We require such service providers to contractually commit to safeguards designed to protect the security and confidentiality of personal information they process on our behalf.
b) Business Partners
We share personal information with third-party Business Partners when this is necessary to provide our Services to our customers. Examples of third parties to whom we may disclose personal information for this purpose are Business Partners that promote and/or offer the same conservation or assistance programs we offer that are beneficial to customers. Our Business Partners may include energy utilities that share eligibility for alternative rates assistance programs; and key manufacturer and retail partners in the promotion of voluntary conservation programs.
c) Our Customers and Other Third Parties Authorized by Our Customers
You may be presented with an option on our Sites to receive certain information and/or marketing offers directly from Business Partners or other third parties, or to have us send certain information to Business Partners or other third parties or give them access to it for the purpose of providing information to you. If you choose to do so, your personal information and other information may be disclosed to such partners or other third parties, and the disclosed information will also be subject to the privacy policies and practices of those third parties.
d) Corporate Transactions
In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business—such as a reorganization, merger, consolidation, restructuring, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, interests, and/or assets—we may share personal information with third parties for the purpose of facilitating and completing the transaction.
e) Compliance and Harm Prevention
To the extent permitted by applicable law, we share personal information as we believe necessary (i) to comply with applicable federal, state, and local laws; (ii) to enforce our contractual rights; (iii) to protect or defend the rights, privacy, safety, and property of Golden State Water, you, or others; and (iv) to respond to requests from the CPUC or courts, law enforcement agencies, regulatory agencies, and other public and government authorities.
5. Your Rights Regarding and Choices About the Information We Collect
a) California Privacy Rights
If you are a California resident, you may submit a request to exercise these rights by calling the Customer Service Center at 1-800-999-4033, emailing firstname.lastname@example.org, or submitting this online webform.
b) Opting Out of Receiving Electronic Communications From Us
If you would like to stop receiving newsletters or other marketing or promotional messages, notifications, or updates from us, you may do so by clicking the unsubscribe link that appears at the bottom of any of these email communications or by emailing us at email@example.com, and we will promptly remove you from all correspondence. Please be advised that you may not be able to opt-out of receiving certain service or transactional messages from us.
c) Viewing or Changing Your Account Information
To update or change your contact information, log in to your MyGSWater account and make changes in your profile settings, or contact us by emailing firstname.lastname@example.org and/or calling 1-800-999-4033.
6. Security and Retention
We implement technical and organizational safeguards designed to protect and secure your personal information. We have taken steps to ensure that the only personnel and contractors who are granted access to your personal information are those who have a business-related need to know or whose duties reasonably require such information.
Please note, however, that no data that is transmitted over the internet, mobile networks, or wireless networks or that is stored electronically can be guaranteed 100% secure. As a result, we cannot guarantee or warrant the security of any information you transmit to or from our Site.
We keep your personal information for different lengths of time depending on the type of information and the business and legal requirements. For example, if you are a customer, we keep information that personally identifies you as long as you remain a customer of our Services. If you are no longer a customer of our Services, we may be still required to retain that information for business and legal purposes. Other information is deleted automatically after a certain period of time, often set by law, unless we are legally required to hold it for a longer time period. We destroy, deidentify, or anonymize the information when it is no longer needed in identifiable form.
7. Protecting the Privacy of Minors
Our Sites and Services are not directed to or intended for use by any children under the age of 16, and we request that they not provide personal information through the Sites and Services.
In the event that we become aware that we have collected personal information from a child under the age of 16, we will take steps to dispose of that information as permitted by law and in accordance with the Children’s Online Privacy Protection Act and other applicable laws and regulations. If you are a parent or guardian and you believe that your child under the age of 16 has provided us with personal information without your consent, please contact us by calling the Customer Service Center at 1-800-999-4033 or emailing email@example.com.
9. Contact Us
For more information about our privacy practices, or if you have questions or concerns, please contact us by calling the Customer Service Center at 1-800-999-4033, emailing firstname.lastname@example.org, or mailing us at the address provided below:Golden State Water Company
Attn: General Counsel
630 E. Foothill Blvd.
San Dimas, CA 91773