At Smart Earth Technologies 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.
1. WE COLLECT INFORMATION ABOUT YOU FROM YOUR WATER SERVICE PROVIDER AND DIRECTLY FROM YOU WHEN YOU USE OUR SERVICES.
“Personal Data” means data that allow 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 are associated with or linked to any of the foregoing data. “Anonymous Data” means data that are not associated with or linked to your Personal Data. Anonymous Data do not permit the identification of individual persons. All Personal Data are kept strictly confidential and are used solely to provide authorized Services to you and/or your Water Service Provider and enhance such Services. We collect Personal 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 are collected, mobile telephone or landline telephone number, email address, account number, billing and payment history and current billing information, water audit data, and prior participation in utility 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 activate or 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, mobile telephone or landline telephone, password, and, optionally, household information such as number of occupants, landscape characteristics, and water- and energy-using fixtures in your house. With your Water Service Provider’s authorization, if you elect to use our Site to facilitate payment of utility bills, a third party payment processor may on our Site or its site also collect from you personal financial information such as credit card, debit card, or bank account numbers and related information. If you use our Site without signing up for an Account, you may elect to provide us with your email address or telephone numbers for use with alerts and notifications that you opt into.
(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.
2. HOW WE USE PERSONAL DATA, ANONYMOUS DATA AND AGGREGATE DATA
(a) In general, Personal Data we collect are used to provide our Services, including to process your water use data or respond to requests that you make, or to aid us in serving you better. SET 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.
You may have the option to designate additional users on our Site. Please give careful consideration to any such person before making this optional choice. Additional users you designate will be able to view on our Site all information and Personal Data which you can view.
(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; and we may use Anonymous Data for any other legitimate business purpose not restricted by contract. 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 become 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 do not contain personally identifiable information, and we may use aggregate data for any legitimate business purpose not restricted by contract. The disclosure and use of aggregate data is governed by our contract with your Water Service Provider.
3. 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 are 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. If our facilitation of payment of utility bills is authorized by your Water Service Provider and elected by you, for your convenience we may share necessary Personal Data with a third party payment processor. This is for your convenience to help avoid the need to re-enter or duplicate information already provided. In addition, regardless of any choices you make regarding your Personal Data (as described below), SET 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 SET or assist law enforcement authorities, or in any litigation involving SET.
4. 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, (iii) to help you and their other customers conserve water, and (iv) facilitate presentment and payment of your utility bills and balances. The privacy policies of your Water Service Provider will apply to its use and disclosure of your Personal Data.
5. YOU MAY OPT OUT OF RECEIVING EMAILS AND OTHER COMMUNICATIONS 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. SET 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.
6. WE DO OUR BEST TO KEEP YOUR DATA SECURE
SET 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 SET cannot fully eliminate security risks associated with Personal Data and security breaches are possible.
Smart Earth Technologies, LLC.
Attn: Customer Service
1959 Kellogg Avenue
Carlsbad, CA 92008