SouthWest Water Company and its affiliates and related entities (collectively, “SWWC”, “We”, “Us, “Our”) are serious about protecting our customers’ privacy. We understand your concerns about how we collect, share or use information about you and we appreciate your trust that we will do so carefully and sensibly. This Privacy Policy (“Privacy Policy”) provides details about information we obtain from our customers as well as visitors to our websites, including www.swwc.com and any successor replacement sites (“Site”). This Privacy Policy is also incorporated into and is a part of the Site’s Terms of Use. We encourage you to become familiar with the terms and conditions of both this Privacy Policy and the Terms of Use. SWWC reserves the right to change this Privacy Policy at any time by posting a new privacy statement at this location. By continuing to access or use the Site, products, or services, you acknowledge you’ve reviewed and agree to this Privacy Policy.
For purposes of this Privacy Policy and related policies:
- “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 particular consumer or household. Personal Information includes information that identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household. This includes any information you provide, information automatically collected about you, and information from third parties. Aggregated, de-identified, or anonymized information and publicly available information lawfully made available from federal, state, or local government records are not Personal Information.
- “Service Providers” are Third Parties that process information on our behalf to whom we disclose Personal Information for a business purpose pursuant to a written contract that limits the Service Provider’s right to retain, use, or disclose Personal Information for any purpose other than to provide services to us under the contract or otherwise specified under the law.
- “Contractors” means vendors, agents, contractors, or partners that provide service to or on behalf of SWWC or our business partners.
- “You” and “Your” means any of our customers or visitors to or users of the Site or other online services we provide.
Information We Collect
Information You Provide
To provide you with water and/or wastewater utility and related services, we receive, collect, store, use, and process information, including Personal Information, that you give or make available to us based on our business relationship with you, or by using or accessing the Site or other online services. This information includes, but isn’t limited to:
- The information you provide when you start water and/or wastewater utility service, such as your name, home and mailing addresses, phone number(s), email address(es), and/or the last 4 digits of your Social Security Number (“SSN”).
- Billing and payment information you use to pay your water and/or wastewater utility bill, such as your financial information (e.g., banking and credit card information), payment history, and/or the last 4 digits of your SSN.
- Information you provide to determine eligibility for certain programs or services, including household income, the number of people living in your home, 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.
- Information you use to visit, register for, manage, or access your SWWC account, including your account number, name, address, phone number(s), and email address(es).
- Information you provide on any electronic or paper form, including electronic or paperless billing, service alerts, or authorization for someone else to manage your account.
Information Through The Site
Your access or use of the Site: We collect information about visits to or use of the Site, such as the number of visitors that click on certain links or use certain services. We use standard industry software to create summary statistics of the collected data, which may then be used to highlight what visitors or users of the Site may find interesting, to improve the design and usability of the Site to identify system performance issues, or for other internal purposes.
Log data: We receive information that’s recorded when you visit or use the Site, including your Internet Protocol (“IP”) Address, which is a number automatically assigned to your computer or mobile device every time you browse the Internet. We might use the IP Address to help diagnose technical problems or to administer the Site. We may also use the IP Address to provide localized content to you on the Site related to your geographic location. Please note, however, that the IP Address is not associated with your Personal Information and we don’t use it to identify you when logging IP Address data.
Additional information that might be automatically recorded and collected when you visit or use the Site or other online services includes the type of Internet browser and operating system you’re using; the name of your Internet service provider and domains used by them; device identifiers (such as an Apple IDFA or an Android Advertising ID); device and browser settings; the websites visited before or after you visit the Site; the type of handheld or mobile device you used; location information; and the content and advertisements you might have accessed, seen, forwarded, or clicked.
Cookies: A cookie is a small piece of data sent to your browser from a web server and stored on your computer or other device that makes your use of some online services more convenient. When you visit or use the Site or other online services, cookies are generated and placed on your device. We use cookies and similar technologies and might allow our business partners to do the same. This allows us to provide targeted information to you about programs or services we or our business partners offer. It may be possible for you to disable the use of cookies through your browser settings.
If you do not want your information to be collected through cookies, you can change the preferences in your Internet browser. Key website functionality associated with our customer self-service portal will not work properly if your browser does not accept cookies. Specifically, if you choose not to accept our cookies and are a registered user, you will not have access to your information, such as your user profile, account information, payment features and other general account information, on this site. In addition, our “Guest” payment feature may not function properly if our cookies are not accepted. Please consult your chosen Internet browser for instructions on how to change your cookie settings.
Geolocation information: If you visit or use the Site or other online services from a mobile device, you might be asked to share your 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 might be able to turn off such data collection at a later time by accessing the settings on your device or mobile application.
How We Use Your Information
We receive, collect, store, use, and process information you provide or make available to us for the following general purposes:
- To provide water and/or wastewater utility and other related services to you, administer your account, bill you for services, and process your payments.
- To improve our operational efficiency and to provide you with better service.
- To authenticate and verify your identity when you contact us or when you access your account.
- To communicate with you about your account or services, including responding to your contacting us.
- To send you information about programs or services that may be of interest to you.
- 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.
Who We Disclose Your Information To
We don’t and won’t sell or share your Personal Information. To provide you with services or to complete transactions you request, we might disclose your Personal Information to Contractors and Service Providers who act on our behalf, including:
- Our affiliates, per this Privacy Policy.
- Service Providers or Contractors, to provide, maintain, and improve our services, including service providers who help us with IT/network infrastructure, payment processing, data security, customer support, data analytics, communications, or otherwise.
- Contractors you asked us to provide your information to.
- Contractors in connection with a merger, sale of company stock or assets, financing, acquisition, divestiture, or dissolution of all or a portion of our business.
- Contractors, 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 regulatory authorities and other city, state or federal government agency with legal authority to obtain your Personal Information from us.
We don’t disclose Personal Information to any other person or entity without your prior consent, including electronically, except as necessary for us to:
- Provide water and/or wastewater utility and related services to you.
- Operate and maintain our water systems.
- Comply with a valid warrant, subpoena, or court order.
- Comply with a valid request from a regulator or other state or federal government agency with legal authority to obtain Personal Information from us.
- Enable Third Parties to provide services to you on our behalf, but only to the extent necessary to provide those services and subject to appropriate confidentiality and security requirements.
- Notify credit reporting agencies and collection agencies, if your account is assigned for collection.
- To protect the personal safety of our customers, employees, or the public.
- Assist emergency responders in situations of immediate threat to life or property.
- To protect and defend our rights and property.
Communications
We use contact information you provide us, including email addresses and phone numbers, to communicate with you about your water and/or wastewater utility and related services and programs, including service interruptions, system improvements, and other aspects of the services we provide. This section of the Privacy Policy gives information about how we plan to interact with you, including as may be applicable, through voice, text messages, emails, and other forms of digital communication.
Email Communications – Terms of Use
Implied Consent: By providing us with your email address(es), you authorize us to contact you by email as a primary form of contact method when available, unless you select an alternative preference.
We might now or in the near future send you service-related email messages and other information about new and/or existing programs and services, including information about billing, service interruptions or system improvements, conservation and rebate programs, water quality, regulatory filings, utility rates, and other information related to your business relationship with us.
By providing us your email address(es), (i) you acknowledge and represent that you’re the authorized user of the email address(es); (ii) you give us express permission to send emails to the email address(es) until you revoke that permission; and (iii) you’re asking 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 won’t be in violation of such list(s).
Opt-Out: You can opt-out of receiving some emails from us by (i) changing your communication preferences in your online account or the relevant SWWC program account or website. Changing your communication preferences will disable the email message(s) for that particular program only. We reserve the right to (i) send you certain required and/or transactional emails and (ii) respond by email to your emails or other electronic communications means regardless of whether you opted out of receiving other emails from us.
No Warranties: We make no representations or warranties about email alerts, notifications, or other communications. We disclaim all warranties, including any implied representations or warranties of merchantability or fitness for a particular purpose.
Text Alerts – Terms of Use
Consent: By providing your mobile device number(s) and activating text alerts (if available or applicable) on your online account, through a SWWC customer care representative, or through any other SWWC program that provides for text alerts or notifications, (i) you acknowledge and represent that you are the authorized user of the mobile device(s) that you link to the text alert service or that you’ve been given permission by the authorized user of the mobile device(s) to enroll the mobile device(s) in the service; (ii) you give us 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 giving such permission you are asking 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 (if available and as applicable) either (i) disabling the alerts from your online account or the relevant SWWC program account or Site. 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. Please note that we reserve the right to send you any required 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 any applicable regulatory agencies, and/or other required communications that you won’t have the option to opt-out from.
No Warranties: We make no representations or warranties about text alerts or notifications or other digital communications. We disclaim all warranties, including any implied representations or warranties of merchantability or fitness for a particular purpose.
Telephone Communications
We use the phone number(s) you provide to communicate with you about your water and/or wastewater utility and related programs and services and other aspects of the services we provide. We do not engage in telemarketing, and any communication with you via telephone is conducted in accordance with the Telephone Consumer Protection Act (TCPA) and applicable state laws. To learn more about the TCPA and applicable state laws, you may visit the Federal Trade Commission’s TCPA webpage at www.fcc.gov/cgb/consumerfacts/tcpa.html.
Social Media Sites
We may use social media sites (e.g., Facebook and Twitter) 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 don’t 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
While visiting or using the Site or other online services, you may encounter and choose to access websites or other online services that we don’t own or operate or isn’t otherwise associated with us by clicking on hypertext links or icons. We don’t control and aren’t responsible for what others do in connection with their websites, mobile applications, or other online services, or how they handle your Personal Information. You should carefully review the privacy policies and terms of use of these other websites and applications.
“Do Not Track” Signals
The Site and other online services we provide don’t respond to “Do Not Track” signals, requests, or other similar mechanisms.
Information Retention
We retain Personal Information and other information you provide or otherwise make available to us, actively or passively, based on legal requirements or recommendations, including those from applicable regulators, or as long as is reasonably necessary to provide you with water and/or wastewater utility and related services.
Security
We maintain appropriate physical, technical and administrative safeguards to protect the security and confidentiality of your Personal Information. But no data transmission over the Internet or a wireless network can be guaranteed to be 100% secure. As such, we can’t guarantee the security of any information you send us electronically and you agree that you do so at your own risk. We can’t and don’t assume responsibility for the use or disclosure of your information resulting from unauthorized or illegal access to our systems or those of our vendors, agents, contractors, affiliates, or partners.
Children
The Site isn’t intended or designed for children and we don’t collect Personal Information from children, including anyone we know to be under the age of 13. If we learn that a child under 13 submits information through any part of the Site, we will attempt to delete this information as soon as possible. By accessing and using the Site, you affirm that you are at least 18 years old, an emancipated minor, possess legal parental or guardian consent, or are accompanied by a legal parent or guardian, and are fully able and competent to agree to the terms of this Privacy Policy and the Terms of Use. If you are a parent or guardian of a child and believe the child has given us Personal Information, please contact us at Privacy@swwc.com to let us know.
For California Customers Only – CPRA Notice
The California Privacy Rights Act (“CPRA”) gives California residents additional privacy rights, subject to certain exceptions and limitations. If you are a California resident, you have the right to make the following requests:
- Notice: We are required to notify you before we collect your Personal Information or Sensitive Personal Information of the information we collect, the purpose of collecting it, and how long we retain that information.
- Access: You can ask us for the categories and specific pieces of Personal Information we have collected about 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 we have shared Personal Information during the 12 months preceding your request.
- Correction: You have the right to ask us to correct any inaccurate personal information, taking into account the nature of the personal information and the purposes of processing that personal information.
- Delete: You can ask us to delete your Personal Information under certain circumstances. Please note that we won’t be able to honor deletion requests in many cases, including when we need to keep the information to: (i) complete a transaction or otherwise perform a contract between you and us (e.g., continue to servicer your account and provide water service); (ii) detect or protect against security incidents or fraud; (iii) comply with a legal obligation, including those imposed by the California Public Utilities Commission; and/or (iv) otherwise internally use your Personal Information in a lawful manner that’s compatible with the context in which you provided the information.
About the Sale or Sharing of Your Personal Information
We do not sell or share your Personal Information or Sensitive Personal Information, as those terms are defined by the CPRA. Because we do not sell or share your personal information, there is no need for our customers to exercise the right to opt out of the sale or sharing of Personal Information or Sensitive Personal Information.
To request access to your Personal Information, correct inaccurate Personal Information, or delete your Personal Information, please contact us through any of the following:
- Web Form: www.swwc.com/ccpa-requests/
- Phone: 800-203-5430
- In Person – Suburban Water Systems:
- San Jose Hills District Office:
1325 N. Grand Avenue, Suite 100
Covina, CA 91724 - Whittier/La Mirada District Office
15088 Rosecrans Avenue
La Mirada, CA 90638
- San Jose Hills District Office:
Consistent with the CPRA, we don’t discriminate against California consumers who exercise their CPRA rights. To protect you and your Personal Information, we will take reasonable steps to verify your identity when you make a CPRA request using the information we have associated with your account, including account numbers, service and billing addresses, email addresses, and phone numbers. We may also contact the customer of record by telephone and in writing to verify your identity, using the information associated with your account. You can also authorize someone you trust to submit a request on your behalf, as long as you give that person written permission to make the request for you and that person is able to adequately verify their identity to us. We can also respond to requests from authorized agents who submit a power of attorney under the California Probate Code that you provide to them.
If you need access to this Privacy Policy or a CPRA request form in an alternative format due to any disability, please contact us through the methods provided above.
CPRA Summary – Categories of Personal Information Collected, Sources of Collection, Business Purposes, and With Whom Shared
Categories of Personal Information Shared Within the Last 12 Months | Sources of Collection | Business or Commercial Purposes |
Category of Third Parties With Whom Personal Information Is Disclosed, If Disclosed, Within the Last 12 Months. |
Identifiers: This can include: real name, alias, postal address, unique personal identifier, online identifier, partial social security numbers, date of birth, driver’s license number, passport number, Internet Protocol address, email address, account name, or other similar identifiers. | On the Site, calls and interactions with customer care and field services staff, applications and enrollment forms | Used for general business purposes for providing customer service, including creating, maintaining, customizing and securing your account with us and processing payments. | Service Providers or Contractors |
Personal Records: This can include physical description of characteristics, signature, telephone number, education, employment, employment history, insurance policy number, bank account number, credit card number, debit card number, or any other financial information medical information, or health insurance information. | On the Site, calls and other interactions with customer care and field services staff, applications and enrollment forms | Used for general business purposes for providing customer service, including creating, maintaining, customizing and securing your account with us and processing payments. | Service Providers or Contractors |
Personal Characteristics or Traits: This can include gender, marital status, religion, veteran status, familial status, race, disability, gender identity, and creed. | Calls and other interactions with our customer care and field services staff | Used for general business purposes for providing customer service, including creating, maintaining, customizing and securing your account with us and processing payments. | Service Providers or Contractors |
Customer Account Details / Commercial Information: This can include records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | On the Site, calls and other interactions with our customer care and field services staff, applications and enrollment forms. | Used for general business purposes for providing customer service, including creating, maintaining, customizing and securing your account with us and processing payments. | Service Providers or Contractors |
Water Usage Information: This can include parcel number, addresse, account number, installation number, rate category, and usage information. | On the Site, calls and other interactions with our customer care and field services staff, applications and enrollment forms. | Used to comply with franchise agreements or ordinances that require the sharing of water usage data with municipalities. | Municipalities |
WISH Customer Information: This includes names, service addresses, and billing addresses of customers who participate in our WISH (Water Invoice and Statement Help) Program. | On the Site, calls and other interactions with our customer care and field services staff, applications and enrollment forms, including the WISH application form. | Used to comply with California Public Utilities Commission Decision 11-05-020 (Decision Adopting Guidelines for Sharing of Low-Income Customer Information), requiring water and energy utilities to share low-income customer information. | Gas and electric utilities subject to California Public Utilities Commission Decision 11-05-020 (Decision Adopting Guidelines for Sharing of Low-Income Customer Information) whose service areas overlap our service areas. |
Internet Usage Information: This can include browsing history, search history, and information regarding your interaction with a website, application, or advertisement. | On the Site | May be used for internet browsing analytics. | Service Providers or Contractors |
Sensory Data: This can include audio recordings of customer care calls, electronic, visual, thermal, olfactory, or similar information. | Calls and other interactions with our customer care and field services staff | Used for general business purposes, including creating, maintaining, customizing and securing your account with us and providing customer service. | Service Providers or Contractors |
Contact Us
For more information about this Privacy Policy, you can contact us at:
SouthWest Water Company
12535 Reed Road
Sugar Land, TX 77478
Attn: General Counsel
Email: Privacy@swwc.com
Changes and Updates to Privacy Policy
We reserve the right to change this Policy at any time at our sole discretion. Such changes will be effective immediately upon posting to the Site or being otherwise provided to you. Your use of the Site and our services after such changes have been posted will constitute your acceptance of all provisions of the then revised Privacy Policy.
Privacy Policy Last updated: December 30, 2022