Last Revised: July 1, 2023
This Privacy Notice describes:
- the information that The Connecticut Water Company, The Maine Water Company, The Avon Water Company, and The Heritage Village Water Company (collectively, “Water Companies” or “we” or “us” or “ours”) collect from you when you interact with any one of our websites, including www.ctwater.com, www.mainewater.com, www.avonwater.com, and www.heritagevillagewater.com (collectively “Websites”);
- how we collect, use and disclose the information that we receive, including any sharing of such information with third parties; and
- how we store and secure such information.
How to Contact Us
If you have any questions, concerns or complaints about this Privacy Notice, our data collection or processing practices, if you would like to review your personally identifiable information (“PII”), request a change to your PII or contact preferences or if you want to report any suspected security violations to us, please contact us at: Connecticut Water, Attn: Public Affairs, 93 West Main Street, Clinton, CT; or via telephone at 1.800.286.5700; or via email at firstname.lastname@example.org.
Services We Provide
We offer the following services (“Website Services”) on our Websites:
- We provide information about the water-related services we offer as well as information about conservation, water quality, special offers and programs (e.g., the Linebacker Protection program) and current news and events related to the Water Companies.
- We also provide customers of the Water Companies the option to pay their bill on-line and we offer several fillable forms that address common customer issues or inquiries such as service inquiries or property closing information.
- We promote career opportunities and invite on-line applications.
- We provide investors and potential investors information regarding investment opportunities, investor rights and other related topics.
Information We Collect
Information You Provide to Us. We will collect data from you that you voluntarily provide.
a. Contact Us. If you provide us with feedback or contact us through our “Contact Us” button or via email, we will collect the information that you provide to us, which may include your name, address, telephone number and email address, as well as any other content you include, and we will use that information to respond to your message.
b. Forms. Our Websites offer several forms designed to assist our customers including but not limited to forms for meter reading, property closing, service inquiry and Linebacker Protection enrollment. If you complete a form on our Website, we will collect and use the information you provide to us on that form to respond to your request or inquiry or complete requested enrollment. Customers are not required to use the on-line forms.
c. Newsletters/Communications. You can subscribe to newsletters or email lists on our Websites. If you choose to register to receive a newsletter or email alerts or updates, we will collect your email address, first and last name, and address and we will then send you a verification email.
Information We Receive From Your Use of Our Websites.
Links to Third Party Websites
How We Use and Share Your Information
We use your information only for purposes of providing the Website Services described above or to otherwise comply with our legal obligations. We do not sell your information to anyone. Specifically, we may use or share your information as detailed below.
With your consent. We may share your information with third parties if you have given us your consent to do so.
To perform services. We may use or disclose your information to third parties in order to provide water-related services or to provide Website Services you request, such as to enroll you in the Linebacker Protection program.
To communicate with you. We use your information to communicate with you about our Website Services, planned service interruptions, water main flushing schedules and other information about your water service with the Water Companies, and also to respond to you when you contact us or to solicit your feedback. If you provided us with an email address, we may also send newsletters, surveys, offers, and other promotional materials related to our Website Services and for other marketing purposes of the Water Companies. You can control these marketing communications by unsubscribing at any time through our Websites or by using the “Unsubscribe” link in our email.
With our affiliates. We may share your information with our parent company, subsidiaries, joint ventures or other companies under common control (“Affiliates”), in which case, we will require our Affiliates to adhere to this Privacy Notice.
With third party service providers performing services on our behalf. We may share information with our third party service providers to perform the functions for which we engage them. We may share information as needed to operate other related services. For example: (1) we may share information about you with Google Analytics so that Google Analytics can provide us with information about the usage of our Websites; and (2) once you indicate interest in and complete an enrollment form for the Linebacker Protection program, we will share that information with our Affiliate, New England Water Utility Services, Inc. (NEWUS) to process your enrollment.
To improve, personalize, and develop Website Services. We use the information we collect to improve and personalize Website Services and to develop new services and benefits.
To create anonymous data. We may remove all identifying information from your data to create anonymous data and aggregate that data with other anonymous data. We may use and disclose any such anonymous information without restriction.
For corporate/regulatory purposes. We may share some or all of your information to the extent necessary with regulatory or other government authorities or with third-party entities with which we are negotiating a transaction, such as a sale, merger or acquisition, and which is subject to a confidentiality agreement. If another entity acquires us (or any of our Affiliates), that entity will possess the information we collected (or relevant portion thereof) and will assume the rights and obligations regarding your information as described in this Privacy Notice.
For legal purposes. We may preserve or disclose information about you to comply with a law, regulation, legal process, or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, or threats to the security of the Website Services or any other services of the Water Companies, or the physical safety of any person.
Your Options Regarding Your Information
Change Your Information
All users may review, update, correct or delete the information collected through our Websites by contacting us at 1.800.286.5700 or email@example.com. If you are or have been a customer and wish to remain a customer, the Water Companies must maintain basic account information to provide services to you.
If you need further assistance regarding your options, please contact us and we will consider your request in accordance with applicable laws.
We retain PII we collect through our Websites for as long as needed to provide the Website Services to you. We will retain and use this PII (i) as necessary to comply with our legal obligations, (ii) to resolve disputes, (iii) to enforce our agreements with you, and/or (iv) for the period required by laws in applicable jurisdictions.
We use a combination of technical, administrative, and physical controls to maintain the security of your data. If you have a security-related concern, please contact us. In order to protect you and your information, we may suspend your use of any of our Website Services, without notice, pending an investigation, if we suspect any breach of security.
Our Websites are not intended for use by children. Children under thirteen (13) should not send any information about themselves to us. We do not collect PII from any person that we know to be under the age of thirteen (13). If we learn that a child under thirteen (13) has submitted information to us through our Websites, we will attempt to delete this information as soon as practicable.
How We Respond to Do Not Track Signals
“Do Not Track” signals are used by some web browsers to attempt to limit tracking related to your visits to a website. We take no action in response to Do Not Track signals, headers, or other similar mechanisms.
Changes to this Privacy Notice
We may update this Privacy Notice from time to time for any reason. We will notify you of any changes to our Privacy Notice. Our notification may include a notice on the Website, an email notification or by posting the new Privacy Notice with a revised “Last Updated” date above. You should consult this Privacy Notice regularly for any changes. You can then decide whether you would like to continue to use the Website Services.
Connecticut Privacy Notice
Last updated: 7/1/2023
This Connecticut Privacy Notice (the “CT Notice”) supplements the information contained in our Privacy Notice above and applies solely to individual residents of the State of Connecticut (“consumers” or “you”).
This CT Notice describes how we collect, use, disclose, and otherwise process personal data of individual residents of the State of Connecticut within the scope of the Connecticut Data Privacy Act (“CTDPA”). Unless otherwise expressly stated, all terms in this CT Notice have the same meaning as defined in our Privacy Notice or as otherwise defined in the CTDPA.
What is Personal Data?
When we use the term “personal data” in this CT Notice, we mean any data that is linked or reasonably linkable to an identified or identifiable individual. “Personal data” does not include deidentified data or publicly available information.
Collection, Use, and Disclosure of Personal Data. We collect various categories and types of personal data from a variety of sources and for a variety of purposes.
To learn more about the types of personal data we collect, the purposes for which we use and disclose personal data, and the third parties to whom we may disclose personal data, please review the Information We Collect and How We Use and Share Your Information sections of the Privacy Notice.
Sales of Personal Data and Sharing for Targeted Advertising. Where permitted by applicable law, and as further described in the How We Use and Share Your Information section of the Privacy Notice, we may “sell” your personal data (as defined by the CTDPA) to third parties, or share your data for with third parties for targeted advertising purposes, subject to your right to opt out (see Your Privacy Choices below).
We have sold or shared the following categories of personal data for the purposes described in our Privacy Notice, subject to your settings and preferences and your Right to Opt-Out: Online identifiers such as IP address.
The categories of third parties to whom we may sell or share the personal data include:
Online Advertising Networks and Analytics Providers
We may also disclose personal data for the purposes described in the How We Use and Share Your Information section of our Privacy Notice. In addition, please see the Third-Party Data Collection and Online Advertising section of the Privacy Notice to learn more about how third-party advertising networks, social media companies and other third party businesses collect and disclose your personal data directly from your browser or device through cookies or tracking technologies when you visit or interact with our services or otherwise engage with us.
The following personal data elements we collect may be classified as “sensitive” under certain privacy laws (“sensitive data”):
- Mental or Physical Health Condition or Diagnosis;
- Consumer Health Data;
- Precise Geolocation Data.
We only use or disclose sensitive personal information for the following purposes, where such use or disclosure is necessary and proportionate for those purposes: for performing services you have requested, for detecting security incidents, fraud and other illegal actions, to ensure the physical safety of natural persons, or to perform services on behalf of the business.
We do not sell sensitive data, and we do not process or otherwise share sensitive data for the purpose of targeted advertising. However, subject to certain legal limitations and exceptions, you may be able to withdraw your consent for our processing of sensitive data (as described in the Your Privacy Rights section below).
We may at times receive, or process personal data to create, deidentified data that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified data, we will maintain and use the information in deidentified form and not attempt to reidentify the information except as required or permitted by law.
Your Privacy Rights
Subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:
The Right to Access & Portability
The right to confirm whether we are processing personal data about you and the right to access such personal data we have collected about you and, where required by law, the right to obtain a copy of the personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
The Right to Correction
The right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of the personal data.
The Right to Deletion
The right to request the deletion of personal data that we maintain about you, subject to certain exceptions.
The Right to Opt Out of Sales or Sharing for Targeted Advertising Purposes
The right to direct us not to process your personal data for purposes of targeted advertising or for personal data sales.
The Right to Withdraw Consent
If you have provided consent for the processing of your personal data, you may have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our use of your personal data before your withdrawal.
The Right to Appeal
In the event that we decline to take action on a request exercising one of your rights set forth above, you have the right to appeal our decision.
You may also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, the exercise of the rights described above may result in a different price, rate or quality level of product or service where that difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by law.
How to Exercise Your Privacy Rights
Please submit a request by either:
- Emailing us at firstname.lastname@example.org with the subject line, “Consumer Rights Request,”
Before processing your request, we will need to verify your identity and confirm you are a resident of a state that offers the requested right(s). In order to verify your identity, we will generally either require the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems, such as invoice number or amount.
You do not need to create an account with us to exercise your rights; however, this process may require us to request additional personal data from you, including, but not limited to, your email address, phone number, date of last transaction on our services, or matching of sufficient information you provide to us to the information we maintain about you in our systems.
In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.
Submitting Authorized Agent Requests
In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we may require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.
To Exercise Your Right to Opt-Out of Sale or Processing for Targeted Advertising Purposes
Where permitted by applicable law, unless you have exercised your Right to Opt Out, and as described in the Sales of Personal Data and Sharing for Targeted Advertising section of this CT Notice, we may disclose or “sell” your personal data to third parties for monetary or other valuable consideration in relation to online tracking technologies, or process your personal data for targeted advertising purposes. The third parties to whom we sell or share personal data may use such information for their own purposes in accordance with their own privacy policies.
The third parties to whom we sell or share personal data may use such information for their own purposes, in accordance with their own privacy statements, which may include reselling or sharing this information to additional third parties.
Appealing Privacy Rights Decisions
In the event that we decline to take action on a request exercising one of your rights set forth above, you have the right to appeal our decision. All appeal requests should be submitted by emailing us at email@example.com with the subject line, “Privacy Request Appeal.”
If your appeal is denied, you may contact the Connecticut Attorney General to submit a complaint here.
Our services are not directed to, and we do not intend to, or knowingly, collect or solicit personal data from children under the age of 13. If an individual is under the age of 13, they should not use our services or otherwise provide us with any personal data either directly or by other means. If a child under the age of 13 has provided personal data to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal data from our systems. If we learn that any personal data we collect has been provided by a child under the age of 13, we will promptly delete that personal data.
Updates to this CT Notice
We may update this CT Notice from time to time. When we make changes to this CT Notice, we will change the date at the beginning of this CT Notice. If we make material changes to this CT Notice, we will notify individuals by email to their registered email address, by prominent posting on our services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.
If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to firstname.lastname@example.org