­­PRIVACY POLICY FOR CALIFORNIA RESIDENTS

Effective Date: January 1, 2020

Last Updated: April 2, 2020

This Privacy Policy applies to any California residents about whom we have collected personal information from any source, including through your use of our Sites, by receiving our services, participating in one of our programs, or by communicating with us electronically, in paper correspondence, or in person (collectively, “you”). We provide this Privacy Policy to comply with applicable privacy laws, including the California Consumer Privacy Act of 2018 (“CCPA”). Any capitalized term used and not otherwise defined below has the meaning assigned to it in the­­­ online Privacy Policy.

The CCPA provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of “personal information,” as well as rights to access, delete, and restrict the sale of certain personal information we collect about them. California residents also have the right not to receive discriminatory treatment by us for the exercise of your privacy rights under the CCPA. If you are a California resident, you may submit a request to exercise these righ­­ts by calling our Customer Service Center at 1-800-999-4033. You may also email a completed online webform to ccparequest@gswater.com or mail it to the address provided below in Section II(e). For more information about our general privacy practices, please view our online Privacy Policy.

If you are a visually-impaired customer, a customer who has another disability or a customer who seek support in other language, you may access Golden State Water’s Privacy Policy for California Residents by con­­­tacting the Customer Service Center at 1-800-999-4033 or emailing customerservice@gswater.com.

I. DEFINITIONS

For the purposes of this Privacy Policy, except where a different definition is noted, “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 California consumer/resident or household. Personal information does not include publicly available information, information that has been de-identified or aggregated, or other information covered by certain sector-specific privacy laws.

II. CCPA DISCLOSURES AND RIGHTS

a. Personal Information We Collect

Golden State Water may collect, or has collected, the following categories of personal information about you over 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 Site by you or others to be featured on our Site;
• 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.

b. What We Do With Your Information

Golden State Water may collect or use personal information about you for the following business purposes:

• Provide water utility services to you (such as starting or stopping your service), administer your account, and to bill you for services.
• Operate and maintain safe, secure and reliable water utility services and equipment.
• Improve our operational efficiency and provide you with better services and programs.
• Contact you in response to an inquiry that you sent.
• Send you messages and information related to your water utility services and programs, support and administrative messages, technical notices, updates, alerts, and other information.
• Send you information about services and programs we offer that may be of interest to you.
• Notify credit reporting agencies and collection agencies, if your account is assigned for collection.
• Comply with request or order from courts, law enforcement or other government authorities
• Assist emergency responders in situations of threat to life or property

Golden State Water may also use personal information for other business purposes, including the following: (i) audit; (ii) compliance with our legal obligations or to assert or defend a legal claim; (iii) general business administration; (iii) processing employment applications; and (iv) systems and data security.

c. Sources of Collected Information

We may collect personal information from the following categories of sources:

• From you, including via our Sites, telephone, postal mail, social media, forums, or other means;
• From our utility meters and other equipment, such as water usage information collected by our meters.
• Our service providers, which includes 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, which includes energy utilities sharing eligibility for alternative rates assistance programs; key utility, manufacturer and retail partners in the promotion of voluntary conservation programs
• Other third parties, which includes payment portals you opt to use outside of those authorized by us, operators of other websites and mobile applications, online advertising partners, and other data suppliers;
• Other sources, including things that other third parties may post publicly about you or otherwise provide to us; and
• Government entities, including city services providers and regulators.

We may supplement the information described above with information we obtain from other sources, including from both online and offline data providers.

d. Who We Share Your Information With

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. Golden State Water also does not have actual knowledge that it sells the personal information of minors under 16 years of age.

We disclose the following categories of personal information to the provided categories of third parties for a business purpose:

Categories of entities	Categories of personal information disclosed
Service providers, vendors, contractors, and suppliers that provide services, products, programs and equipment on our behalf or support Golden State Water’s general business operations	Identifiers, commercial information, geolocation information, and/or other personal information
Business partners that promote and/or offer the same conservation or assistance programs we offer that are beneficial to customers	Identifiers, commercial information, and other personal information including consumption information
Our internet service providers	Information relating to Internet activity or other electronic network activity
Government entities receiving personal information pursuant to a request or order from courts, government agencies (such as the California Public Utilities Commission and California Water Commission) or by law enforcement or other government authorities; or as necessary for Golden State Water to defend or assert legal claims	Identifiers, commercial information, and other personal information including consumption information
Financial institutions, credit agencies, and other financial services entities providing financial and auditing support services for Golden State Water’s water utility programs and services	Identifiers, commercial information, and other personal information including consumption information

e. Your Privacy Rights

If you are a California resident, you have the following rights under applicable California law in relation to your personal information, subject to certain exceptions:

• Right to Know. You have the right to, up to twice in a 12-month period, request what personal information we collect, use, disclose, and/or sell, as applicable.
• Right to Delete. You have the right to request under certain circumstances the deletion of your personal information that is collected by us.
• Right to Opt-Out of Sale. You have the right to opt-out of the sale of your personal information by a business. However, Golden State Water does not sell your personal information to third parties, and so you cannot exercise this right with us.
• Right to Non-Discrimination. You have the right not to receive discriminatorytreatment by us for the exercise of the privacy rights described above.

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 in this Section II(e). 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 preceding receipt of a Verifiable Consumer Request for a period covering twelve (12) months and for no more than twice in a twelve-month period. Golden State Water reserves the right to extend the response time by an additional forty-five (45) days when reasonably necessary and provided consumer notification of the extension is made within the first forty-five (45) days.

If you are a California resident and wish to exercise these rights, please reach us by calling the Customer Service Center at 1-800-999-4033. You may also email a completed online webform to ccparequest@gswater.com or mail it to the address provided below:

Golden State Water Company

PO Box 9016

San Dimas, California 91773

f. How To Contact Us

If you have any questions or concerns about this Privacy Policy or our privacy practices, please contact us by calling the Customer Service Center at 1-800-999-4033 or emailing customerservice@gswater.com.

III. CALIFORNIA “SHINE THE LIGHT” LAW

California residents additionally have the right to request information regarding third parties to whom Golden State Water has disclosed certain categories of personal information during the preceding year for the third parties’ direct marketing purposes under California’s “Shine the Light” law (Cal. Civ. Code §1798.83). Personal information under this California law means “any information that when it was disclosed identified, described, or was able to be associated with an individual.” We do not disclose this type of personal information to third parties for their own purposes and we permit you to opt out of any disclosures of non-identifiable personal information. However, if you are a California resident and would like to inquire further, please email customerservice@gswater.com.