How We Use and Protect Customer Information
Last updated: January 1, 2020
“Our,” “We,” and “Us” mean California Water Service Company and our affiliated or related companies.
“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. When other information is directly associated with Personal Information, that information may also be considered Personal Information. 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. Publicly available information that is made available from federal, state, or local government records, also is not Personal Information.
“Third Parties” means vendors, agents, contractors, or partners that provide service to or on behalf of Cal Water, or Cal Water’s business partners.
“Website” means Cal Water’s website, www.calwater.com, and other websites owned or operated by Cal Water.
“You” and “Your” means any Cal Water customer or visitor to or user of Cal Water’s website, mobile applications, or other online services.
Categories of Information that Cal Water Collects
Information that you provide to Cal Water
In order to provide you with service, Cal Water receives, collects, stores, uses, and processes information, including Personal Information, that you make available to us based on our business relationship with you, or by using or accessing our website, mobile application, or other online services.
This information includes, but is not limited to:
- The 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 you use to pay your water utility bill, such as your financial information (e.g., banking information), credit history, or the last 4 digits of your Social Security Number.
- Information you provide to determine eligibility 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 information may include education related information, for example, related to scholarships.
- 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.
- Information you provide on any form on our website, mobile applications, 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.
Cal Water may supplement the aforementioned 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 website or mobile applications
Your visits to or use of Cal Water’s website or mobile applications: Cal Water collects information about visits to or use 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 then be used to highlight what visitors to or users of the website or mobile applications may find interesting, to improve the design and usability of the website or mobile applications, to identify system performance issues, or for other internal purposes.
Log data: We receive information that is automatically recorded and collected when you visit or use our website or mobile applications, including Your Internet Protocol (“IP”) Address. An IP Address is a number automatically assigned to your computer or mobile device every time you browse the Internet. We may use Your IP Address to help diagnose problems with the servers or to 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 geographic location. Your IP Address is not associated with your Personal Information and we do not use it to identify you when logging IP Address data.
Additional information that may be automatically recorded and collected when You visit or use our website, mobile applications, or other online services includes, but is not limited to, the type of Internet browser You are using (e.g., Chrome, Safari, Firefox, Internet Explorer), the type of operating system You are using, (e.g., Microsoft Windows or Mac OS); the name of Your Internet service provider (e.g., Comcast, Verizon or AT&T) and domains used by such providers; device identifiers (such as an Apple IDFA or an Android Advertising ID); Your device settings, Your Internet browser settings; the websites You visited before You visit our website; the websites You visit after You visit our website; the type of handheld or mobile device used to view the website (e.g., iOS, Android); location information; and the content and advertisements You have accessed, seen, forwarded and/or clicked on.
Geo-location information: If You visit or use our website, mobile applications, or other online services from a mobile device (e.g. iPhone), you may be asked to share your precise, GPS-level 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 Information
Cal Water receives, collects, stores, uses, and processes the information that you provide or otherwise make available to us, either actively or passively, for the following general purposes:
- To provide water utility or other services to you, administer your account, and to bill you for services.
- To improve our operational efficiency and to provide you with better service.
- To verify your identity when you contact us.
- To contact you in response to an inquiry that you send to Cal Water, or otherwise communicate with you.
- To send you information about programs and services we offer that may be of interest to you.
- To authenticate and confirm your identity when you access your Cal Water account, or make a request.
- To send you messages and information related to your water utility services, support and administrative messages, technical notices, updates, alerts, and other information.
- To comply with legal requirements, or assert or defend a legal claim.
How We Share Your 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 order to provide you with services or to complete transactions requested by you, we may transfer your Personal Information to Third Parties who act on our behalf, including the following:
- Third Parties to provide, maintain, and improve our services, including third party service providers who assist us with network infrastructure, payment processing, security, customer support, data analytics, marketing, or otherwise.
- Third Parties with whom you have requested that we share information, in order to fulfill services you request.
- Third Parties in connection with, or during the negotiation of, any merger, sale of company stock or assets, financing, acquisition, divestiture, or dissolution of all or a portion of our business.
- Third parties as reasonably necessary (a) to comply with any applicable law, regulation, legal process or governmental request; (b) to enforce or comply with our Terms & Conditions 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. These parties may include the California Public Utilities Commission, or other city, state or federal government agency with legal authority to obtain the Personal Information from Cal Water.
Third Parties acting on Cal Water’s behalf are required to follow the same privacy and security policies as Cal Water and its employees, and are subjected to an extensive review of their data handling processes before Cal Water shares Personal Information with them.
Cal Water does not share or release Personal Information to any other person or entity without your prior consent, including electronically, except as necessary for Cal Water to:
- Provide water utility services to you.
- Operate and maintain our water systems.
- Comply with a valid warrant, subpoena, or court order.
- Comply with a valid request from the California Public Utilities Commission, or other state or federal government agency with legal authority to obtain the Personal Information from Cal Water.
- Enable Third Parties to provide services to you on behalf of Cal Water, but only to the extent necessary to render those services and subject to confidentiality and security requirements imposed by Cal Water on the Third Parties.
- Notify credit reporting agencies and collection agencies, if your account is assigned for collection.
- To protect the personal safety of our customers or employees, or the public.
- Assist emergency responders in situations of immediate threat to life or property.
- To protect and defend the rights and property of Cal Water.
Communications With You and Your Related Rights
Cal Water uses contact information you provide to us, including email addresses and mobile phone numbers, to communicate with you about your water utility services, programs and services we offer, service interruptions, water system improvements, and other aspects of the services we provide. This section of the Policy provides detailed information about how we plan to interact with you through voice, text messages, emails, and other forms of digital communication.
Implied Consent: By providing Cal Water with your email address(es) when you establish your Cal Water account online, in-person, or by phone, sign-up for electronic or paperless billing, establish an online account, update your Cal Water account, or sign up for any other Cal Water program or service that provides for communication by email, you are authorizing Cal Water to contact you via email as a primary form of contact method when available, unless you select an alternative preference as indicated in your online account or as part of the relevant Cal Water program or service.
Cal Water may send service-related email messages and other information regarding new and/or existing Cal Water programs and services, including billing information, information about service interruptions or water system improvements, information about water conservation and rebate programs, water quality information, information about regulatory filings, information about water utility rates, and other information related to your business relationship with Cal Water. For example, if you provide your email address(es) to Cal Water through a Cal Water program account or website, such as signing up for a rebate program, Cal Water may send service-related messages and other relevant information regarding new and/or existing Cal Water programs and service to you, unless you select alternative preferences or otherwise “unsubscribe” from email distribution, as described below.
By providing your email address(es) to Cal Water, (i) you acknowledge and represent to Cal Water that you are the authorized user of the email address(es) that you provide; (ii) you grant Cal Water express permission to send emails to the email address(es) you provide until such permission is revoked in accordance with these terms and conditions; and (iii) by granting such permission you are requesting to receive such email messages even if the email address(es) you provide appear(s) on a federal or state Do Not Contact list and you agree that such email messages shall not be in violation of such Do Not Contact list(s).
Opt-Out of Email Communications: You can opt-out of receiving some emails from Cal Water by either (i) changing your communication preferences in your online account or the relevant Cal Water program account or website, or (ii) clicking the Unsubscribe and/or Opt-Out link(s) at the bottom of most emails you receive from Cal Water. Changing your communication preferences or clicking the Unsubscribe and/or Opt-Out Links in an email you receive from Cal Water will disable the email message(s) for that particular program or promotion only. You agree that your prior express consent to receive email messages from Cal Water continues indefinitely unless you cancel your prior express consent using one of the methods described above.
Cal Water reserves the right to send you certain required and/or transactional emails, and also reserves the right to respond via email to inquiries you send to us via email or other electronic means regardless of whether you have opted out of receiving other emails from Cal Water.
Message Frequency: Message frequency depends on the type of email alerts, notifications, or other email communications you choose to receive and the nature of your utility service.
Changes in Terms: Cal Water reserves the right to change these terms or cancel email alerts or notifications or other email communications at any time. Please check these Terms and Conditions on a regular basis for changes. Your continued use and acceptance of email alerts or notifications or other email communications after changes to the Terms and Conditions changes are posted will mean that you accept the terms as modified.
No Warranties: Cal Water makes no representations or warranties whatsoever regarding email alerts or notifications or other email communications. Cal Water hereby disclaims all warranties, including any implied representations or warranties of merchantability or fitness for a particular purpose.
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 email alerts or notifications or other email 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.
Governing Law: These terms shall be construed in accordance with the laws of the State of California, and any arbitration or judicial proceedings to enforce or interpret the terms hereof may be brought only in the State of California.
Consent: By providing your mobile device number(s) and activating text alerts on your online account, through a Cal Water customer service representative, or through any other Cal Water program that provides for text alerts or notifications, (i) you acknowledge and represent to Cal Water that you are the authorized user of the mobile device(s) that you link to the text alert service or have been granted permission by the authorized user of the mobile device(s) to enroll the mobile device(s) in the service; (ii) you grant Cal Water express permission to send text messages to the mobile device number(s) you provide through your wireless carrier unless and until such permission is revoked in accordance with these terms and conditions; and (iii) by granting such permission you are requesting to receive such text messages even if the mobile device number(s) you provide appear(s) on a federal or state Do not Call list and you agree that such text messages shall not be in violation of such Do Not Call Lists. Mobile devices include but are not limited to mobile cell phones, smart phones, tablets, and/or other such devices.
Stop Text Alerts: Text alerts may be canceled by either (i) disabling the alerts from your online account or the relevant Cal Water program account or website, or (ii) by replying “STOP” to the alert from your mobile phone. Replying “STOP” to an alert will disable the alert for that particular program only. You agree that your prior express consent to receive text alerts continues indefinitely unless you cancel your prior express consent using one of the methods described in the prior sentences.
Cal Water reserves the right to send you certain required and/or transactional text messages, including but not limited to, emergency and safety notifications, important information or disclosures about your account, information about credit collections, service interruption notifications, 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.
Pricing: Cal Water does not charge a fee for text alerts. Check with your wireless carrier for your plan details. Should you change carriers, it is your responsibility to check with your new wireless carrier for plan details. Message and data rates may apply.
Message Frequency: Message frequency depends on the type of text alerts or notifications or other digital communications you choose to receive and the nature of your utility service.
Changes in Terms: Cal Water reserves the right to change these terms or cancel text alerts or notifications or other digital communications at any time. Please check these Terms and Conditions on a regular basis for changes. Your continued use and acceptance of text alerts or notifications or other digital communications after Terms and Conditions changes are posted will mean that you accept the terms as modified.
No Warranties: Cal Water makes no representations or warranties whatsoever regarding text alerts or notifications or other digital communications. Cal Water hereby disclaims all warranties, including any implied representations or warranties of merchantability or fitness for a particular purpose.
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 text alerts or notifications or other digital 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.
Governing Law: These terms shall be construed in accordance with the laws of the State of California, and any arbitration or judicial proceedings to enforce or interpret the terms hereof may be brought only in the State of California.
Cal Water uses the phone number you provide to us to communicate with you about your water utility services, programs and services we offer, service interruptions, water system improvements, and other aspects of the services we provide. Cal Water does not engage in telemarketing, and any communication with you via telephone is conducted in accordance with the Telephone Consumer Protection Act and applicable state laws. Third Parties that conduct telemarketing in reference to a product or marketing initiative of Cal Water are required to adhere to the Telephone Consumer Protection Act and applicable state laws. To learn more about the Telephone Consumer Protection Act and applicable state laws, you may visit www.fcc.gov/cgb/consumerfacts/tcpa.html.
Targeted Communications on Social Media Sites
Cal Water uses social media sites – such as Facebook, Twitter, YouTube, Instagram – to communicate with you about our programs and services. You can choose to follow us on these social media sites to receive information about our programs and services. These sites also may allow us to provide targeted information to you using the information they maintain about you, even if you do not specifically follow us on their site. We may target information to you using information we have collected from you such as cookies, pixels, zip codes, email addresses, and interests. You may be able to disable some or all of this targeted information by adjusting your privacy settings on the respective social media sites.
Links to other websites, mobile applications, or other online services
While visiting or using Cal Water’s website, mobile applications, or other online 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
Our website, mobile applications, and other online services do not respond to “Do Not Track” signals, requests, or other similar mechanisms.
We retain Personal Information and other information you provide or otherwise make available to us, either actively or passively, based on legal requirements or recommendations, including those from the California Public Utilities Commission, or as long as is reasonably necessary to provide water utility service to you.
We understand how important your privacy is, which is why we maintain—and expect the same from our service providers—appropriate physical, technical and administrative safeguards to protect the security and confidentiality of the Personal Information you entrust to us.
Please keep in mind that no data transmission over the Internet or any wireless network can be guaranteed to be 100-percent secure. As a result, we cannot guarantee the security of any information you transmit to us, and you transmit such information at your own risk. Cal Water does not assume responsibility 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.
Areas of our website, mobile applications, and other online services are intended for use by children, their parents or guardians, or teachers, and contain information about water use and conservation. We do not monitor the age of users of our website, mobile applications, and other online services, and 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 email@example.com.
Your California Privacy Rights
Under California Civil Code section 1798.83, California resident customers with whom we have an established business relationship are entitled, once per calendar year, to ask us for a notice identifying the categories of personally identifiable information that we share with our affiliates and/or third parties for marketing purposes, and to provide contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to us at the following address:
California Water Service Company
1720 North First Street
San Jose, CA 95112
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, following a verifiable request, to:
- access—twice in a 12-month period, free of charge—the categories and specific pieces of Personal Information Cal Water has 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, for the 12-month period prior to the request; and
- delete Personal Information under certain circumstances. Please note that we will not be able to honor deletion requests in all cases, including when your Personal Information is subject to a statutory exception. Those exceptions include, for example, when we need to retain the information to: (i) complete a transaction or otherwise perform a contract between us and the consumer; (ii) detect or protect against security incidents or fraud; (iii) comply with a legal obligations; and/or (iv) otherwise use the your Personal Information internally in a lawful manner that is compatible with the context in which the consumer provided the information.
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 firstname.lastname@example.org;
- 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, correct, or delete.
Cal Water does not discriminate against you for exercising your rights afforded by the CCPA, which is further in accordance with California residents’ rights under that title. In order to adequately protect your Personal Information, we will take steps to verify your identity. You may also authorize an agent to submit a request on your behalf, so long as you provide the authorized agent written permission to request on your behalf, and your authorized agent is able to verify their identity with our third party identification service. Alternatively, we will respond to requests from authorized agents who submit evidence that you have provided them with power of attorney pursuant to the California Probate Code.
Should you need access to this policy in an alternative format due to a disability, please contact us through the methods provided above.
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. Your use of our services after such changes have been posted shall constitute your acceptance of all provisions of the revised Policy.