Privacy Policy

This Privacy Policy governs how Smart Energy Water, LLC. ("SEW", "we", "our" or "us"), uSEW Personal Information obtained from Clients and Customers, and website visitors who use our products and services, including our mobile software applications that are used in connection with our products (collectively, our “Service”). Furthermore, this Privacy Policy explains what Personal Information we receive and collect about (1) our Clients and their personnel (“Personnel”); (2) the customers of our Clients ("End Customers"), and (3) visitors to our website, in addition to how we use, process, retain, and transfer such Personal Information. SEW is fully committed to maintaining robust privacy protection and management of any Personal Information that is shared with us as a result of using our Service. As used in this Privacy Policy, "Personal Information" means any information that may be used, either alone or in combination with other information, to personally identify an individual, including, but not limited to, a first and last name, a phone number, an email address, and other contact information.

  1. End User License Agreements. Where applicable, this Privacy Policy forms part of the Software as a Service Agreement or other licensing agreement that we enter into with our Clients. Capitalized terms not defined herein shall have the meaning ascribed to them in the Service Agreement.
  2. Modification and Changes in Policy. SEW reserves the right, at our discretion, to change the terms of this Privacy Policy at any time. Such change will be effective ten (10) days following the earlier of: (1) our posting of the revised Privacy Policy on our website at www.smartesys.com (the “Site”) or (2) an email notification to our Clients.
  3. Collection and Receipt of Personal Information. We may receive and/or collect Personal Information in the following ways:
    1. Client Account Set-Up and Account Use: SEW may collect certain Personal Information that a Client chooses to provide about its Personnel as part of setting up and maintaining a Client account to use the Service. This Personal Information may include a user ID, name, email address, phone number, address, information about a Personnel’s skills and professional experience, and other Personal Information that the Client chooses to make available in connection with its, and its Personnel’s, use of the Service. In order to access and use the Service, a separate user name and password will be created for individual Personnel.
    2. Location Based Services and Personnel: Some of SEW’s Service products (individually “Location Based Service”) are dependent on data related to the geographic location of the mobile device on which the Service is being used by Personnel ("Location Data"). We use various technologies to determine location, such as global position system (GPS) signals, Wi-Fi access points, and cell tower ids. If you choose to use these Location Based Services, you agree that we may receive Location Data. If you don’t want us to receive your Location Data, you may re-configure the settings on your mobile device to turn off location-sharing features. However, please be aware that turning off device location-sharing features may result in the inability to use our Location Based Service and your (and our Client’s) use of the Service may be negatively impacted. Thus, please consult with your employer or organization prior to turning off any device-based location services.
    3. Personnel Mobile Device Data: In addition to Location Data, we may collect other limited information from the mobile device of Personnel who are using our Service. Such information may include the Personnel’s user name, mobile device type, mobile device id, the date and time stamps of Service usage, and browser information.
    4. End Customers: As part of providing our Service to a Client, we may collect certain Personal Information that a Client chooses to provide about its End Customers. Such information may include an End Customer’s name, email address, phone number, fax number, and other Personal Information that the Client chooses to make available in connection with its use of the Service.
    5. Log Files: Our Service may make use of log files. The information inside the log files may include internet protocol (IP) addresSEW, application times taken to process Service user requests, Service user action details along with input parameters for debugging, Device IDs, public telephone numbers (PTNs), browser types, date/time stamps, referring/exit pages, clicked pages and any other information that a browser may send to us.
    6. Cookies: The Service may utilize SEWsion "cookies" for authentication validation purpoSEW. A "cookie" is a small text file that may be used, for example, to authenticate access to the Service. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. Please be aware that if you choose to block a cookie, your login attempt to the Service may be unsuccessful.
  4. The Way We Use Personal Information.
    1. Client and Personnel Information: We only use the Personal Information of a Client and its Personnel to: (1) contact the Client, (2) provide our Service to the Client, and (3) to identify and authenticate the Client's and its Personnel’s access to our Service.
    2. End Customer Information: We only use the Personal Information of an End Customer to provide the Service to the Client that is related to that End Customer. In connection thereto, we may disclose an End Customer’s Personal Information to the Client (and its Personnel) that is related to that End Customer.
    3. Affiliates: We may transfer Personal Information to the subsidiaries and affiliated companies (each an “Affiliate”) that are within the SEW group of companies, but only for the purpose of providing our Service. Such information may be transferred to other countries around the world in which we have Affiliate offices, including the USA and India. Our Affiliates are required to process any such Personal Information in compliance with this Privacy Policy. Notwithstanding the foregoing, we will comply with applicable laws regarding Personal Information transfers as well as any transfer restriction that is specified in a specific Service Agreement between SEW and a Client.
    4. Partners and Third Party Providers: We may transfer Personal Information to our third party service providers and partners, but only for purpoSEW of carrying out our business operations and to enable us to provide our Service. Such information may be transferred to other countries around the world. Notwithstanding the foregoing, SEW will comply with applicable law regarding Personal Information transfers as well as any transfer restriction that is specified in a specific Service Agreement between SEW and a Client. We use commercially reasonable efforts to only engage or interact with third party service providers and partners that also instate a privacy policy governing their use and processing of Personal Information.
    5. Retention of Personal Information: We reserve the right to retain any Personal Information and other Service-related data in order to: (1) fulfill the purpoSEW that are described in this Section 4 of this Privacy Policy, and (2) to comply with applicable law.
    6. Other Disclosures: We may disclose your Personal Information or any information that is submitted to us via the Service if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our End User License Agreement, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of SEW, our users, or the public.
  5. Anonymous Information. Anonymous Information means any information which does not enable identification of an individual user, such as aggregated information, about use of the Service. We may use Anonymous Information (defined below) or disclose it to third party service providers, to provide, improve and develop our Service, including analyzing trends and gathering demographic information.
  6. Push notifications. If you access the Service via your mobile device, you may receive push notifications from SEW or your employer/organization. If you no longer wish to receive push notifications, you disable them by re-configuring the settings on your mobile device to turn off push notifications for a specific mobile application. However, please be aware that if you choose to turn off push notifications, your (and our Client’s) use of the Service may be negatively impacted. Thus, please consult with your employer or organization before turning off push notifications.
  7. Opting-Out of Promotional Emails. You may choose not to receive future promotional or advertising emails from us by selecting an unsubscribe link at the bottom of each email that you receive from us. Please note that even if you opt out of receiving the foregoing emails, we may still send you a response to any "Contact Us" request as well as administrative, maintenance and operational emails (for example, in connection with a password reset request) that are necessary to facilitate use of the Service.
  8. Client Choice. Each of our Service users may choose whether or not to provide or disclose Personal Information in connection with its use of the Service. If a Service user chooses not to provide the Personal Information we request, it may still visit and use parts of the Service, but may be unable to access or use certain features, options, programs, and services that involve our interaction.
  9. Access and Accuracy - Clients. To the extent that we are provided with Personal Information, we wish to maintain accurate Personal Information. Our Clients may log into their Service account and use the Service tools to access or correct a material inaccuracy in certain Personal Information that we may be storing. If a Client would like to access, delete or correct any other Personal Information that we may be storing, the Client may submit an access request by sending an email to legal@smartenergywater.com. The email should include adequate details of the request.
  10. Access and Accuracy - End Customers and Personnel. As required by law, we provide individuals (including End Customers and Personnel) with the right to access, correct, or delete any of their Personal Information that we may be holding. Any such request should be forwarded to legal@smartenergywater.com. The email should include adequate details of the request, and we may ask for an identity verification before acting on a request. We may request that an individual first attempt to resolve their concern (and show proof thereof) with the Client that provided, or made available, the information to us. We may reject a request for certain reasons, in accordance with an exemption that is permitted under applicable law, for example if the request is fraudulent, vexatious, extremely impractical, risks the privacy of others, or requires disproportionate technical effort. Please be aware that, in accordance with applicable law, we may charge a fee to act on a request that would require a disproportionate effort.
  11. Links to Other Sites and Third Party Advertisements. Third party advertisements may appear on some pages of the Service, for example on the Service account log-in page. Such third party advertisements, and other parts of the Service (for example, the Service account log-in page) may also contain links to third party websites and services that are not owned or controlled by SEW. We are not responsible for the privacy practices or the content of third party websites, services and advertisements, and you visit them at your own risk.
  12. Enforcement/Verification. SEW uSEW the self-assessment approach to verify our compliance with this Privacy Policy. To do so, we conduct periodic compliance audits of our privacy practices. If we become aware that any of our employees or third party service providers are using or disclosing Personal Information in a manner that violates this Privacy Policy, we will take reasonable steps to prevent or stop the use or disclosure.
  13. Dispute Resolution. Please feel free to direct any questions or concerns you may have regarding the use or disclosure of Personal Information to SEW’ Privacy Officer at legal@smartenergywater.com. SEW will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles contained in this Privacy Policy.
  14. Security. The security of Personal Information is important to us. We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Personal Information, we cannot guarantee its absolute security.
  15. Privacy for Children. SEW’s Service is not designed to be directed towards children under the age of 18. As such, we do not intend to knowingly collect Personal Information from any person who is under 18 years of age.
  16. In the Event of Merger, Sale, or Change of Control. SEW may transfer or assign this Privacy Policy and any Personal Information to a third party entity that acquires SEW or is merged with as a result of a merger, acquisition, sale, or other change of control.
  17. How We Respond to Do Not Track Signals. SEW does not track Service users over time and across third party websites to provide targeted advertising. Accordingly, we do not currently respond or take any action with respect to web browser "do not track" signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information about an individual consumer's online activities over time and across third-party web sites or online services.
  18. Contacting SEW. Any comments, concerns, complaints, or questions regarding our Privacy Policy may be addressed to the SEW Legal Department at legal@smartenergywater.com.

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