Privacy Policy

Post

Effective Date: January 1, 2023

Last Updated: August 26, 2024

Golden State Water Company, its parent company, and its affiliates (“Golden State Water,” “we,” “our,” or “us”) believe it is important for us to protect the privacy of our customers.  We provide this Privacy Policy to comply with applicable privacy laws, including the California Consumer Privacy Act of 2018 (“CCPA”). 

This Privacy Policy describes the types of personal information we collect from customers or potential customers and other people with whom we communicate and interact in the course of providing customers with our water utility services and programs (“Services”), and via our website at www.gswater.com and other websites and web-based services that enable website visitors access on our behalf (our “Sites”).  This Policy also describes how we collect and use personal information, under what circumstances we may disclose it and with whom, and your rights and choices. 

This Privacy Policy also does not apply to third-party websites, products, or services, even if they link to our Services or Sites, and you should consider the privacy practices of those third parties carefully. 

We also encourage you to review our Terms of Use which govern your use of the Services and Sites. 

If you are a customer with a visual impairment or other disability or a customer who seeks support in another language, you may access Golden State Water’s Privacy Policy by contacting the Customer Service Center at 1-800-999-4033 or by emailing ccparequest@gswater.com.

This Privacy Policy is provided in a layered format. Please click on a section heading below to link to that specific section.

1. Overview

Golden State Water obtains personal information about you from various sources in order to provide our Services and manage our Sites.  “Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.  “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 Sites.  “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

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”).  In particular, we have collected the following categories of personal data from consumers within the last twelve (12) months:

  • Identifiers, which includes real name and alias; postal address; unique personal identifier; online identifiers as detailed below; IP address or device IDs; email address; home and mailing address; home and mobile telephone number; account number, name, and password; Social Security number; driver’s license number, passport number, consulate number, federal tax ID, state or other government-issued identification card number; and/or other similar identifiers;
  • Commercial information, which includes records of personal property; products or services purchased, obtained, or considered; customer programs participated in; account balances, payment history, or account activity; bank account information and other information relating to your financial institution; and information from credit reporting agencies;
  • Information relating to Internet activity or other electronic network activity, which includes your IP address, cookie identifiers, clear gifs (a.k.a. web beacons/web bugs), browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, clickstream data, device platform, and device version;
  • Geolocation data, which includes Global Positioning System (“GPS”) data based on your meter or premise location;
  • Audio, electronic, or visual information, which includes recordings of calls to or from our customer service centers; video surveillance information; and/or photos of you submitted to our Sites by you or others to be featured on our Sites;
  • Information not listed above and related to characteristics protected under California or federal law, which may include military service when qualifying for military family relief; and
  • Other personal information not listed above and described in California Civil Code § 1798.80(e), which includes signature; bank account number, credit card number, debit card number, and/or other financial information; and medical certifications, if needed.
  • Professional and employment related information, which includes your employment history.
  • Education information, which includes your education history, records maintained by an educational institution, and information about any training or certification programs.

We collect the following types of sensitive personal information:

  • Customer account name, number and password
  • Social Security number, Driver’s license, passport number, or state or other government-issued identification card number
  • Bank account information and other information related to your financial institutions; and
  • Precise geolocation data.

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.
  • If you apply for employment with us, you may be asked to provide certain personal information, including your first and last name, email address, phone number, education information (including your education history, records maintained by an educational institution, as well as information about any training or certification programs), and professional or employment-related information (including your employment history).

If you are an employee, we may collect certain information such as information relating to your compensation and benefits, information relating to your performance evaluations, information concerning time worked (clock ins/outs), and your signature (for timesheets).

b) Personal Information We Collect Automatically on Our Sites

Our Sites use cookies and other tracking technologies, such as web beacons, embedded scripts, pixels, and tags, to function effectively and provide our Services to you, as discussed in more detail in Cookies and Tracking Technologies. 

c) Information From Third-Party Sources

We may also obtain certain information about you from third-party sources, including:

  • From our utility meters and other equipment, such as water usage information collected by our meters.
  • Our service providers, including utility vendors, consultants, or suppliers that provide water-related services or equipment on our behalf; customer relationship management providers; analytics providers; website hosting providers; systems administrators; and communications delivery services;
  • Business partners, including energy utility sharing eligibility for alternative rates assistance programs; key utility, manufacturer and retail partners in the promotion of voluntarily conservation programs;
  • From social media and other content platforms, such as Meta, X, Instagram, or YouTube if you interact with us on these platforms. 
  • Other third parties, including payment portals you opt to use outside of those authorized by us, credit agencies, and other third parties to help us provide and improve the Services;
  • Other sources, including things that other third parties may post publicly about you or otherwise provide to us; and
  • Government entities, including city service providers and regulators

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

We may create deidentified or anonymous data from personal information by removing—or through obfuscation or through other means—data components (such as your name, email address, or linkable tracking ID) that makes the data personally identifiable to you.  Our use of anonymized information is not subject to this Privacy Policy.

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.
  • Improve our operational efficiency and provide you with better services and programs.
  • Interact with you, including to send you direct marketing communications if you consented to us doing so.
  • Send you messages and information related to your water utility services and programs, support and administrative messages, technical notices, updates, alerts, and other information.
  • 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.

Golden State Water may also use personal information for other business purposes, including the following: (i) audit; (ii) general business administration; (iii) processing employment applications; and (iv) systems and data security. 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 your personal information to third parties, or otherwise provide personal information to third parties for a commercial purpose, other than service providers receiving information to perform services on our behalf.  We share your personal information to the provided categories of third parties for a business purpose, as outlined below.

a) Our Marketing Partners

We may share personal data among our various marketing partners, including HomeServe and other water conservation vendors to market their products and services.  If you prefer that we do not share your personal data with our marketing partners, please Contact Us.

b) Service Providers

We share personal information including identifiers, commercial information, geolocation information, information related to internet activity, and/or other personal information with our service providers, vendors, contractors, and suppliers 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.

c) Business Partners

We share personal information, including identifiers, commercial information, and other personal information including consumption 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.

d) 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.

e) 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.

f) Compliance and Harm Prevention

To the extent permitted by applicable law, we share personal information, including identifiers, commercial information, and other personal information including consumption 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 or orders from courts, government entities (such as the California Public Utilities Commission and California Water Commission), law enforcement agencies, regulatory agencies, other public and government authorities, or as necessary for Golden State Water to defend or assert legal claims.

5. Cookies And Other Tracking Technologies 

We use cookies and similar tracking technologies to track activity on our Sites and we hold certain information.  Cookies are files with a small amount of data which may include unique identifier.  Cookies are sent to your browser from a website and stored on your device.  Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Sites.

In addition, third parties may use tracking technologies in connection with our Service, which may include the collection of information about your online activities over time and across third-party websites or online services.  The use of this functionality may involve the third-party site providing information to us.  We may not control those tracking technologies, and these third-party practices are not subject to our Privacy Policy.  We encourage you to review the privacy policies of those third parties carefully.  For example, we may provide links on the Sites to facilitate your sending a communication from the Sites, or we may use third parties to facilitate your interacting with social media sites. 

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent.  Please note that if you disable your browser’s ability to accept cookies, you will be able to navigate GS Water’s website but may not be able to take advantage of all features and will not receive advertisements related to our programs or services which may be of interest to you.

a) Examples of Cookies We Use

  • Strictly Necessary. We may use cookies that we consider are strictly necessary to allow you to use and access our website, including cookies required to prevent fraudulent activity, or improve security.
  • Performance Related. We may use cookies that are useful in order to assess the performance of our website, including as part of our analytic practices or otherwise to improve the content, products or services offered through our website.
  • Functionality Related. We may use cookies that are required to offer you enhanced functionality when accessing our website, including identifying you when you sign in to our website or keeping track of your specified preferences, including in terms of the presentation of content on our website.
  • Targeting Related. We may use cookies to deliver content, including ads, relevant to your interests on our website and third-party sites based on how you interact with advertisements or content.

b) Analytics Information

We also use Google Analytics or other service providers for analytics services on our Sites.  These analytics services may use cookies to help us analyze how users use the Sites and diagnose technical issues.  Information generated by these services (e.g., your IP address, location, time of visit, whether you are a return visitor, and any referring website) may be transmitted to and stored by Google Analytics and other service providers on servers in the U.S. (or elsewhere) and these service providers may use this information for purposes such as evaluating your use of the Services, compiling statistic reports on the Service’s activity, and providing other services relating to Services activity and other Internet usage.  You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on. 

c) Third-Party Ad Networks

Certain companies may participate in the Digital Advertising Alliance (“DAA”) AdChoices Program and may display an Advertising Option Icon for Interest-based Ads that links to an opt-out tool which allows you to exercise certain choices regarding targeting.  You can learn more about the DAA AdChoices Program at http://www.youradchoices.com/ and its opt-out program for mobile apps at http://www.aboutads.info/appchoices.

In addition, certain advertising networks and exchanges may participate in the Network Advertising Initiative (“NAI”).  NAI has developed a tool that allows consumers to opt out of certain Interest-based Ads delivered by NAI members’ ad networks.  To learn more about opting out of such targeted advertising or to use the NAI tool, see http://www.networkadvertising.org/choices/.  Please be aware that, even if you are able to opt out of certain kinds of Interest-based Ads, you will continue to receive non-targeted ads.  Opting out of one or more NAI or DAA members only means that those selected members should no longer under the DAA / NAI rules deliver certain targeted ads to you.  This will affect this and other services but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks).  If your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different device or web browser(s), or use a non-browser-based method of access (e.g., mobile app), your NAI /DAA browser-based opt-out may not, or may no longer, be effective.  Mobile device opt-out will not affect browser-based Interest-based Ads even on the same device, and you must opt-out separately for each device.  We are not responsible for the effectiveness of, or compliance with, any third party opt-out options or programs or the accuracy of their statements regarding their programs.

d) Do Not Track

Your browser or device may include “Do Not Track” functionality.  At this time, the Site does not respond to browser “Do Not Track” signals.

6. Your Rights Regarding and Choices About the Information We Collect

a) California Privacy Rights

The CCPA provides California residents with specific rights regarding their personal data.  If you are a California resident, you may have the following rights under applicable California law:

  • Right to know and access.  You have the right to know what personal data we collect, use, disclose, and sell and/or share, as those terms are defined under applicable law.  You may ask us to provide you a portable copy of this information up to two times in a rolling twelve-month period.
  • Right to delete and erase.  You have the right to request under certain circumstances that we, as well as our service providers and contractors, delete the personal data that we collect about you.
  • Right to correct inaccurate personal data.  You have the right to request the correction of inaccurate personal data.
  • Right to non-discrimination.  You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.
  • Right to opt out of sale and/or sharing.  You have the right to opt-out of the sale and/or sharing of your personal data by a business.
  • Right to limit use and disclosure.  You have the right to limit the use or disclosure of your sensitive personal data to only the uses necessary for us to provide goods or services to you. We will not use or disclose your sensitive personal data after you have exercised your right unless you subsequently provide consent for the use of your sensitive personal data for additional purposes.
  • Sharing with third parties for their own direct marketing purposes.  We do not disclose this personal data to third parties for their own purposes without your consent.  If you wish to request information regarding such practices under California’s “Shine the Light” Law, please Contact Us.  You must include your full name, email address, and postal address in your email or mail request so that we can verify your California residence and respond.

How to exercise your rights. You may exercise any of the rights described in this section by calling the Customer Service Center at 1-800-999-4033, emailing ccparequest@gswater.com, or submitting this online webform.

Any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”) as permitted by the CCPA.  We will not fulfill your request unless you have provided sufficient information that enables us to reasonably verify that you are the consumer about whom we collected the personal information on.  We will match the identifying information provided by the requestor to the personal information provided by the consumer that we already maintain.

You may also authorize someone to exercise the above rights on your behalf.  The authorized agent must meet the agency requirements of the CCPA and related regulations.  The authorized agent may submit a request to exercise these rights by calling our Customer Service Center at 1-800-999-4033 or emailing a completed online webform to ccparequest@gswater.com or mailing it to the address provided below.  We will respond to requests from authorized agents who submit evidence that you have provided them with power of attorney.

The above rights are subject to our being able to reasonably verify your identity and authority to make these requests.  In the event you submit a request to access specific pieces of information for your household or the deletion of personal information about your household that includes a minor under the age of 13, we must receive verifiable parental consent before we can comply with such requests.  These rights are also subject to various exclusions and exceptions under applicable laws.

Disclosures in response will be available within forty-five (45) days of receipt of a verifiable consumer request no more than twice in a twelve-month period.  Golden State Water reserves the right, upon notice, to extend the response time by an additional forty-five (45) days when reasonably necessary.

Disclosure of personal information.  We limit our disclosure of the categories of personal data above to our service providers for one or more business purposes.  “Business purposes” means the reasonably necessary and proportionate use of personal data for our operational purposes, other purposes described in this Privacy Policy, for the operational purposes of our service providers and contractors, as well as other purposes compatible with the context in which the personal data was collected

We may “sell” and/or “share” personal data with third party advertising networks and platforms for purposes of providing targeted behavioral advertising on those platforms.

In the last 12 months (from the last updated date listed at the top of this Privacy Policy), we have “sold” or “shared” the following categories of personal data:

  • Identifiers
  • Commercial information
  • Internet or other electronic network activity information
  • Audio, electronic, visual, or similar information
  • Characteristics of protected classifications
  • Inferences

Notice of right to opt-out of sale/sharing.  California residents may opt out of the “sale” or “sharing” of their personal information.  As noted above, we may “sell” and/or “share” personal information with third party advertising networks and platforms for purposes of providing targeted behavioral advertising on those platforms.  You may opt-out by following the instructions in the online webform or contacting us through the contact methods listed below.

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 customerservice@gswater.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 customerservice@gswater.com and/or calling 1-800-999-4033.

7. 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 obligations or policies, to resolve disputes, and/or enforce legal agreements.  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.  Personal data may also be retained for internal analytics purposes.  This information is retained for a shorter period of time, unless it used to enhance security features or improve the functionality of our Services.  Our determination of precise retention periods will be based on (1) the length of time we have an ongoing relationship with you; (2) whether there is a legal obligation to which we are subject; and (3) whether retention is advisable in light of our legal position, including regard to applicable statutes of limitations, litigation or regulatory investigations.

8. 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 customerservice@gswater.com.

9. Updates to This Privacy Policy

We may update this Privacy Policy from time to time.  The “Last updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised.  Any changes are effective when we post the revised Privacy Policy on the Sites.  If we make material changes to this Privacy Policy that expand our rights to collect new personal information or use personal information differently that we have previously collected about you, we will notify you and provide you with the disclosure by posting it on our Sites and contacting you through your Golden State Water account and/or email address.  We encourage you to review this Privacy Policy often to stay informed of how we may process your information.

10. 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 customerservice@gswater.com, or mailing us at the address provided below:

Golden State Water Company
Attn: General Counsel
630 E. Foothill Blvd.
San Dimas, CA 91773