Privacy Policy
Privacy Policy
Effective: January 1, 2020
Last updated: May 8, 2023
This Privacy Policy describes how San Jose Water Company and our subsidiaries and affiliated companies (collectively, “SJWC,” “we,” or “us”) collect, use, disclose and otherwise process information about you. This Privacy Policy applies to information we collect when you access or use our websites (collectively, the “Website”), our water delivery services (the “Services”), or when you otherwise interact with us, such as through our customer support channels.
We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy. If we make material changes, we will provide you with additional notice (such as by adding a statement to the Services or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.
Content
Targeted Advertising and Analytics
Collection of Information
In this section, we describe the categories of information we collect and the sources of this information, which may vary depending on how you interact with us.
Information You Provide to Us
We collect information you provide directly to us. For example, we collect information directly from you when you create an account, request customer support, or otherwise communicate with us. The categories of information we collect include:
- Security Number: We also generate an ID number that we associate with your account.
- Financial Information: we collect your payment account information, including your routing and account numbers, a voided check, and your signature.
- Property Information: we collect information about your property, including whether it is residential or commercial, the assessor parcel number, the age of the property, and the number of residents.
- Communication Information: we collect information included in your communications to or about us, including if you file complaints or claims.
We may also collect any other information you choose to provide.
Information We Collect Automatically
We automatically collect the following categories of information:
- Transactional Information: we keep a history of your transactions with us, including the dates and amounts paid for the Services.
- Internet Activity Information: we collect information about how you access our Website, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, and browser type. We also collect information about your activity on our Website, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Website.
- Audio Information: If you call our customer service team, we may monitor and retain those conversations.
- Information Collected by Cookies and Similar Tracking Technologies: We use tracking technologies, such as cookies and pixels, to collect information about your interactions with our Website. These technologies help us improve our Website and your experience, see which areas and features of our Website are popular, and count visits. You may be able to adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services.
Information We Collect from Other Sources
We obtain information from other sources. For example, we collect information about your water usage/consumption (“Water Usage Information”) from our meters and related technology and we may collect information about your property from the relevant real estate developer or from public records.
Derived Information
We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your approximate location based on your IP address.
Use of Information
We use the categories of information we collect for the following business and commercial purposes:
- Service Delivery: we use information to provide and maintain our Services, including to deliver water to you, process payments, and authenticate your account.
- Research and Improvement: we use information to analyze and improve our Services, including to test and analyze water system performance, evaluate risk and prioritize assets for maintenance and replacement, and promote efficiency/conservation. We also use information to improve our customer support services.
- Communication: we use information to send you notices of Public Utility Commission hearings, alert you to changes in pressure/contaminants, respond to your complaints, claims, and inquiries, inform you of price changes or the cost for new services, and send you bills or other transactional or relationship messages.
- Marketing and Advertising: we use information to send direct marketing messages. You can opt out of the marketing messages we send by following the instructions in those communications or by contacting us.
- Conducting Analytics: we use information to monitor and analyze Website trends, usage, and activities, improve our Website, and generate de-identified data that we will not attempt to re-identify.
- Protection and Compliance: we use information to make regulatory filings, document and process claims and complaints, detect, investigate, and help prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity, help protect the rights and property of SJWC and others, and comply with our legal and financial obligations.
Disclosure of Information
We disclose the categories of information described above as follows:
- Vendors: we disclose information to vendors, service providers, contractors and consultants that need this information to provide services to us, such as companies that assist us with web hosting, payment processing, fraud prevention, debt collection, customer service, data enrichment, analytics, and marketing and advertising.
- Advertising Partners: we disclose information to third parties for the Marketing and Advertising purposes described above.
- Professional Advisors: we disclose information to our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
- Legal Authorities: we may disclose information to legal authorities and others for the Protection and Compliance purposes described above, including if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements and if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of SJWC, our users, the public, or others.
- Corporate Transactions: we reserve the right to disclose information in connection with, or during negotiations of certain corporate transactions, including the merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
- Affiliates: we reserve the right to disclose information between and among SJWC and any current or future parents, affiliates, subsidiaries, and other companies under common control and ownership.
- Consent: we may disclose information when we have your consent or you direct us to do so.
We also disclose de-identified information that cannot reasonably be used to identify you.
California Residents
This section applies to California residents and describes our data practices today and in the preceding 12 months.
Additional Disclosures
We collect the following categories of personal information: Identifiers, Commercial Information (including the Financial Information, Property Information, Water Usage Information, and Transactional Information described above), Communication Information, Internet Activity Information, Audio Information, and Derived Information. We collect this information from the following categories of sources: directly from you, from real estate developers/public records, and from our water delivery technology. For more information about the specific data points we collect and the sources of such collection, please see the Collection of Information section above.
We collect and disclose personal information for the following business and commercial purposes (described in more detail in the Use of Information section above): Service Delivery, Research and Improvement, Communication, Marketing and Advertising, Conducting Analytics, and Protection and Compliance.
We do not “share” or “sell” personal information. We have disclosed the following categories of personal information to the following categories of recipients (described in more detail in the Disclosure of Information section above):
| Category of Personal Information | Categories of Recipients |
|---|---|
| Identifiers |
- Vendors - Advertising Partners - Professional Advisors - Legal Authorities |
| Commercial Information |
- Vendors - Advertising Partners - Professional Advisors - Legal Authorities |
| Communication Information |
- Vendors - Advertising Partners - Professional Advisors - Legal Authorities |
| Internet Activity Information |
- Vendors - Advertising Partners |
| Audio Information |
- Vendors |
| Derived Information |
- Vendors - Advertising Partners |
Your Privacy Rights
Access, Correction, and Deletion
You have the right to (1) request to know more about and access your personal information, (2) request deletion of your personal information, and (3) request correction of inaccurate personal information.
Visit our privacy portal, email privacy@sjwater.com with the subject heading “California Privacy Rights,” or call our toll-free number at (888) 266-5885 to exercise these rights.
We may verify your request by asking you to provide information related to your recent interactions with us, such as information from a recent bill. If we deny your request, you may appeal our decision by emailing privacy@sjwater.com with the subject heading “California Privacy Rights Request Appeal.”
Nondiscrimination
We will not treat you differently for exercising your privacy rights.
Authorized Agents
If you are submitting a rights request as an authorized agent, you are required to submit proof of your authorization to make the request, such as a valid power of attorney or proof that you have signed permission from the individual who is the subject of the request. Please do not provide any sensitive personal information in connection with this request, such as a driver's license or other government-issued ID. In some cases, we may be required to contact the individual who is the subject of the request to verify his or her own identity or confirm you have permission to submit this request. If you are an authorized agent seeking to make a request, please email privacy@sjwater.com.
Data Retention
We store personal data for as long as necessary to carry out the purposes for which we originally collected it and for other business purposes explained in this Privacy Policy.
Contact Us
If you have any questions about this Privacy Policy, please contact us at privacy@sjwater.com or (888) 266-5885.