California Water Service Company’s Privacy Policy

Last updated: July 1, 2022

California Water Service Company, its affiliates, subsidiaries and related entities (together, "Cal Water," "us" or "we"), is committed to the privacy of our customers, visitors to our websites (www.calwater.com, and other websites owned or operated by Cal Water), users of our mobile applications, stockholders, investors, and investment advisors ("you" or "your"). This Privacy Policy ("Policy") addresses information Cal Water obtains from you in providing water utility, stockholder or other related services (the "Services"). The Policy discloses types of information we collect from you, how information is collected, and addresses the uses and other processing of collected information.

Our Terms of Use, in which this Policy is incorporated by reference, constitutes an agreement between you and Cal Water that conditions your interaction with our Services, where and as permitted by applicable law. By continuing to access or use our Services, you acknowledge that you have reviewed and agree to the provisions of this Policy.

Categories of Information that Cal Water Collects

Information that You Provide to Cal Water

In order to provide you with Services, Cal Water receives, collects, stores, uses, and processes information, including "Personal Information." Personal Information means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a natural person or household. This includes information you provide to us, information which is collected about you automatically, and information we obtain from third parties. Information that is aggregated, de-identified, or anonymized is not considered Personal Information. Information that is made available from federal, state, or local government records, also is not considered Personal Information pursuant to this Policy.

You may make the following categories of Personal Information available to us based on our business relationship with you, including by using or accessing our Services:

  • The Personal Information you provide to Cal Water when you start water utility service, such as your name, home and mailing addresses, home phone number, mobile phone number, email address, date of birth, or the last 4 digits of your Social Security Number.
  • Billing and payment information that you use to pay your water utility bill, such as your financial information (e.g., banking or credit card information), credit history, and the last 4 digits of your Social Security Number.
  • Personal Information provided when you communicate with us—such as when you contact us by phone or email, or join a Cal Water video conference—including voice or image information (including when a call or video conference is recorded), contact information, and the content of the communications themselves. You will always be informed prior to our recording your call or video conference, and you may exit the call or video conference, if you wish not to be recorded.
  • Personal Information you provide to determine eligibility for or participate in certain programs or Services, such as your household income, the number of individuals residing in your home, or your enrollment in other governmental programs (such as food stamps/SNAP, Supplemental Security Income, and the National School Lunch Program), and whether you rent or own your home. Other Personal Information may include education related information, for example, related to scholarships.
  • Personal Information used to visit, register for, manage, or access your Cal Water account, such as your account number, name, address, home phone number, mobile phone number, or email address.
  • Personal Information you provide on any form on our website, mobile applications, survey, poll or otherwise, such as signing up for electronic or paperless billing, alerts regarding service interruptions or water system improvements, or authorizing another person to manage your Cal Water account.
  • Personal Information you provide as a Cal Water stockholder, investor, or investment advisor—including to receive Cal Water stock dividends, receive communications, investor news, updates, filings with the Securities & Exchange commission or other reports, and vote on matters requiring a vote—such as your name, home and mailing addresses, home phone number, mobile phone number, email address, Social Security Number, and financial information.

Cal Water may supplement the aforementioned Personal Information with additional information obtained from other sources, such as online and offline data providers. Such supplemental information may include contact information for you, such as your email address, demographic data, or other relevant information.

Information Cal Water Obtains From Your Use of Our Services

Cal Water collects Personal Information about visits to or uses of our website and mobile applications, such as the number of visitors that click on certain links or use certain Services. Cal Water uses standard industry software to create summary statistics of the collected data, which may be used to improve our website or mobile applications or for other internal purposes.

When you visit or use our website or mobile applications, we also automatically receive some Personal Information, such as your Internet Protocol ("IP") Address and the type of Internet browser, operating system, Internet service provider and handheld/mobile device you are using to view the website or mobile application. We may use your IP Address to help diagnose technical issues or administer the website or mobile applications. We may also use your IP Address to provide localized content to you on our website or mobile applications, which is related to your generalized geographic location.

Cookies: When you visit or use certain of our Services (such as our website(s)), cookies are generated and placed on your device in order to understand information described above, such as how users interact with our website and accounts (including what pages are accessed, and how users interact with the website, accounts and portals). Your browser may give you the ability to control cookies.

Geo-location information: If you visit or use our Services from a mobile device (e.g. iPhone), you may be asked to share your geo-location information so that your experience can be customized. If you agree to the collection of such information at that time, you may be able to turn off such data collection at a later time by accessing the privacy settings on your mobile device and/or through the settings in the applicable mobile application.

How We Use Your Personal Information

Cal Water receives, collects, stores, uses, and processes Personal Information that you provide or otherwise make available to us for the following purposes:

  • To provide Services to you, assist you, administer your account, and bill you for services.
  • To provide, administer, and utilize our websites.
  • To improve our operational efficiency, to provide training, and to provide you with better service.
  • To verify your identity when you contact us, make a request, access your account, vote on stockholder matters or request stockholder information.
  • To contact you in response to an inquiry or otherwise communicate with you.
  • To send you marketing information about our programs and Services that we believe may be of interest to you. If you provide us with your email address, you may be able to opt out of certain types of emails, as described by the communication, or through the account portal.
  • To send you information related to your Services, support and administrative messages, technical notices, updates, alerts, and other information.
  • To provide stockholder support services, administer your account, pay dividends, and send you information about your stock ownership.
  • To perform analyses on the data and other Personal Information we have collected.
  • To prevent potentially fraudulent, prohibited, or illegal activities, and enforce our Terms of Use.
  • To comply with legal requirements, or assert or defend a legal claim.

How We Share Your Information with Third Parties

Cal Water may share your Personal Information with vendors, agents, contractors, or partners that provide service to or on behalf of Cal Water, or Cal Water’s business partners, including cities, sewer and telecommunications providers, credit reporting and collection agencies, or service providers whom you have requested that we share your Personal Information with ("Third Parties"). Cal Water does not sell your Personal Information to Third Parties, and will not sell your Personal Information to Third Parties without your explicit consent. In addition, Third Parties are required to protect your privacy and security, and are subject to review of their data handling processes before we share Personal Information with them.

Cal Water may share or release Personal Information only with your prior consent or in the following circumstances:

  • Provide Services: We may share Personal Information with Third Parties to provide, maintain, and improve our Services. Third party service providers may assist us with, for example, network infrastructure, payment processing, security, customer support, data analytics or marketing.
  • Intra-Agency Public Utility Services: We may share Personal Information with Third Party public utility agencies under confidentiality agreements in order for Third Parties to provide you with other utility services. For example, we may share your address and water usage information with cities or city agencies in order for them to provide you with sewer or sewer related services.
  • Change of Control: We may share Personal Information with Third Parties in connection with, or during the negotiation of, any merger, sale of company stock or assets, restructuring, financing, acquisition, divestiture, dissolution or change of control involving all or a portion of our business, including in connection with bankruptcy or similar proceeding.
  • For Legal Reasons: We may share Personal Information with Third Parties as reasonably necessary (a) to comply with any applicable law, regulation, legal process, valid warrant, subpoena, court order, request from the California Public Utilities Commission, Securities Exchange Commission, or other state or federal government agency with legal authority to obtain Personal Information from us; (b) to enforce or comply with our Terms of Use or other applicable agreements or policies, (c) to protect our rights or property, or the security or integrity of our Services, or (d) to protect us, users of our Services or the public from harm or potentially prohibited or illegal activities.
  • Safety: We may share Personal Information with Third Parties to protect the personal safety of our customers, employees or the public, or to assist emergency responders in situations of immediate threat to life or property.
  • Credit Reporting and Collection Agencies: We may share Personal Information with Third Parties such as credit reporting agencies and collection agencies, if your account is assigned for collection.

Texts and Prerecorded or Artificial Voice Messages

As described above, Cal Water may use Personal Information to communicate with you by text or using prerecorded or artificial voice messages. This section provides additional information and terms relating to those forms of communication.

Consent: By providing your phone device number(s), you agree to receive calls, text messages, and prerecorded/artificial voice messages, including from an automatic telephone dialing system, from or on behalf of Cal Water to your phone number(s) about any matters, including advertisements and marketing. Consent is not a condition of purchasing any property, goods, or services. Message and data rates apply.

Opt-Out: You can cancel messages to your phone by either (i) changing your communication preferences or disabling your alerts in your online account or the relevant Cal Water program account or website, or (ii) replying "STOP" to a text alert from us on your mobile device. Changing your communication preferences, or replying "STOP" to an alert will disable the text message(s) for that particular program or promotion only.

Cal Water reserves the right to send you certain required text messages. These include emergency and safety notifications, important information or disclosures about your account, such as service interruptions or outages, notices mandated by the California Public Utilities Commission and/or other regulatory agencies, and/or other required communications that you will not have the option to opt-out from.

Message Frequency: Message frequency depends on the type of electronic alerts, notifications, or other electronic communications you choose to receive and the nature of your utility service.

Limitation of Liability: To the maximum extent permitted by applicable law, you agree that Cal Water shall not be liable for any direct, indirect, consequential, special, incidental, punitive, or any other damages, even if Cal Water has been advised of the possibility of such damage or loss, arising or resulting from or in any way relating to your use of electronic alerts, notifications or other electronic communications. Cal Water shall not be liable for the acts or omissions of third parties, including but not limited to delays in the transmission of messages due to circumstances out of Cal Water’s control.

Links to Other Websites, Mobile Applications, or Other Online Services

While visiting or using Cal Water’s Services, you may encounter and choose to access websites, mobile applications, or other online services that may not be owned, operated, or otherwise associated with Cal Water by clicking on hypertext links or icons. Cal Water does not control and is not responsible for what outside entities do in connection with their websites, mobile applications, or other online services, or how they handle your Personal Information. Please consult the privacy policies of these other websites, mobile applications, and other online services for further information.

Internet Browser "Do Not Track" Signals and Other Similar Mechanisms

Some browsers have "do not track" features that allow you to tell a website not to track you. These features are not all uniform and certain options you select are both browser and device specific. We do not currently respond to "do not track" signals.

Retention

We retain Personal Information and other information you provide or otherwise make available to us based on legal requirements or recommendations, including those from the California Public Utilities Commission, the Securities & Exchange Commission, and applicable state statutes, or as long as is reasonably necessary to provide Services to you.

Security

We use reasonable procedures and practices to safeguard Personal Information under our control. The Internet, wireless networks and information storage are not 100% secure. We cannot guarantee the security of your Personal Information stored or sent to us. We encourage you to take precautions to protect your Personal Information.

To the maximum extent allowed by applicable law, you agree and acknowledge that Cal Water will not be liable or responsible for use or disclosure of your information that are the result of unauthorized or illegal access to our systems or those of our vendors, agents, contractors, affiliates, or partners. If you have reason to believe that the security of your communications or Personal Information has been compromised, please notify us immediately using the contact information below.

Children’s Privacy

Certain areas of our websites are intended for use by children, their parents or guardians, or teachers, and contain information about water use and conservation for educational purposes, or regarding scholarships. We do not monitor the age of users of our Services, and those areas of our websites are not for commercial purposes. We do not intentionally collect information from children under the age of 13. If you are under the age of 13, you should not submit Personal Information on this website or any other website without the consent of your parent or guardian. If a parent or guardian of a child under 13 believes that the child has provided us with Personal Information, the parent or guardian of that child should contact us at dpo@calwater.com.

We do not sell the Personal Information of any individuals, and therefore necessarily do not sell the information of children of any age.

Your California Privacy Rights

California Consumer Privacy Act

Pursuant to the California Consumer Privacy Act of 2018 sections 1798.100 et seq. ("CCPA"), California residents have certain additional rights in relation to their Personal Information, subject to certain exceptions. For example, you may have may the right to:

1. Access the categories and specific pieces of Personal Information we have collected about the you, the categories of sources from which the Personal Information is collected, the business purpose for collecting the Personal Information, and the categories of third parties with whom Cal Water shares Personal Information.

2. Delete the Personal Information under certain circumstances.

3. Opt out of the sale of personal information. Although this is a right in California, as stated above, Cal Water does not sell your personal information.

Cal Water does not discriminate against our users on the basis of their exercising any of their rights afforded by the CCPA, which is further in accordance with California residents’ rights under the law.

To request access to your Personal Information or delete your Personal Information, you may contact us through any of the following methods:

  • via email at dpo@calwater.com;
  • via phone at (855) 225-9283 (enter the five digits of your zip code or the first three letters of your city, and then select option #6 for CCPA requests); or
  • through our Contact Us form, available at www.calwater.com/ccpa/.

Please specify in your request what Personal Information you would like to access or delete.

We will first acknowledge receipt of your request within 10 business days after receipt of your request. We will provide a substantive response to your request within 45 calendar days after its receipt. If we require more time (up to 90 days or the permitted timeframe), we will inform you of the reason and extension period in writing.

Only you or an authorized agent (as described below) may make a verifiable consumer request related to your Personal Information.

  • How to Authorize an Agent. You may designate an authorized agent to submit your verified consumer request on your behalf, only if the authorized agent has your written permission to do so and you have taken steps to verify your identity directly with us.
  • How We Verify Your Request. To respond to your request we must verify your identity or the authority of your authorized agent. We will only use the Personal Information provided in that context to verify your identity or the authority of your authorized agent to make the request. Making a verifiable consumer request does not require you to create an account with us. To allow us to verify your request, we will require that you provide at least two pieces of Personal Information, including your email address and phone number, we already have in our possession. We will verify your consumer request by comparing the information you provide to information already in our possession, and take additional steps to minimize the risk of fraud.

California’s Shine the Light Law

California Civil Code Section 1798.83, also known as "Shine The Light" law, permits California residents to annually request information regarding the disclosure of your Personal Information (if any) to third parties for the third parties’ direct marketing purposes in the preceding calendar year. We do not share Personal Information with third parties for the third parties’ direct marketing purposes.

Changes to this Privacy Policy

Cal Water reserves the right to change this Policy at any time at its sole discretion. Such changes shall be effective immediately upon posting them to Cal Water’s website, or otherwise providing them to you. If we make any material changes to this Policy, we will provide notice of such changes, as appropriate. Your use of our Services after such changes have been posted shall constitute your acceptance of all provisions of the revised Policy.

Contact

If you have questions regarding our Policy or need to access the policy in an alternative format due to a disability, please contact us at dpo@calwater.com or (855) 225-9283.