HomeServe USA Corp. and its parent, affiliate, and subsidiary entities* (“HomeServe” or “We” or “Us” or “Our”) are serious about the private nature of Your personal data and other information obtained from, or provided by, You (“You” or “Your”) to Us, regardless of the manner in which it is provided, including, but not limited to, information provided by mail, e-mail, telephone, mobile phone (including applications or text message), and through surveys, sweepstakes, contests, Our social media pages, Our mobile applications, or on Our websites (social media pages, mobile applications, and websites are together the “Website” or “Websites”).
In the course of Our business or operating Our Websites, We may access, collect, use, transmit, disclose, store, maintain and otherwise handle personal data about You. This Policy describes the purposes for handling such personal data while ensuring Our compliance with applicable state, provincial/territorial, municipal and federal laws and industry requirements.
This Policy applies to all consumer personal data accessed, collected, used, transmitted, disclosed, stored or maintained by Us, including both electronic data and paper records.
We are committed to using reasonable commercial measures to: (1) safeguard Your personal data, (2) use personal data in accordance with this Policy and all applicable consumer data privacy laws, and (3) monitor and improve the safeguards so they are effective and appropriate. We adhere to the following practices:
· Personal data You provide will be accessed and used in a way that is compatible with this Policy.
· We reasonably protect against unauthorized, inadvertent access, use and/or disclosure through administrative, technical, and physical safeguards.
· We strive to prevent breaches of Your personal data with security measures and will notify You of a breach of Your personal data as required by applicable state, provincial or federal law.
· We train Our employees with regard to safeguarding Your information.
Please do not provide Us with sensitive information or health information. We do not knowingly collect or maintain consumers’ sensitive personal information.
Information We Collect and Use
For purposes of this Policy, “personal data” is any information that directly or indirectly identifies, relates to, or describes an individual or household, or is otherwise defined as “personal information” or “personally identifiable information” under applicable privacy and data protection laws.
In the course of operating Our business and Websites and delivering Our products and services, We collect and process the following categories of personal data collected through various sources, as outlined below. All personal data is collected and processed in accordance with applicable law, including with Your consent where required by applicable law:
1. Through Our Websites and Communications with Us. We collect and store the following personal data when You submit it through Our Websites, and by email and telephone, such as when You enroll in a plan/policy offered by Us. We use this personal data for business and commercial purposes (including to comply with legal obligations and for auditing, security and anti-fraud purposes) and as described more specifically below:
· Personal Identifiers. We receive personal identifiers (which include, for example, Your name, postal address, email address, telephone number, utility account number, policy/account numbers, and other similar identifiers) and use them to respond to and complete Your requests, fulfill Your orders for products and services (e.g., scheduling and dispatching contractors/technicians to provide You with Our services), to fulfill contracts with You, and to communicate with You for informational purposes (including to send You confirmations, technical notices, updates, invoices, surveys, and security alerts) and marketing purposes (including to send You news, promotions, special offers, information, or to offer You other products and services that may be of interest to You). We may communicate with You about sweepstakes or contests, or to process and deliver sweepstakes or contest entries, correspondence, and prizes. We also create internal identification and reference codes to identify You in Our systems.
· Communications and Submissions. We collect the information and content You submit through enrollment forms, email and telephone communications, and Our Websites (including, for example, web chat communications, product and service reviews, social media interactions, contest and sweepstakes entry submissions, and service requests). We use this type of information to provide You the products or services ordered, fulfill contracts with You, to respond to and fulfill Your requests, establish and manage Our customer relations and customer service, and to provide and improve Our Websites and Our products and services.
· Financial Information. We receive financial information (such as, payment card and bank account information, utility account number, and other billing information) to process payments for the products and services You purchase from Us.
· Commercial Information. We collect and generate commercial information and transactional information (such as, records of Your residential status, and records of products and services purchased and received by You). We use this type of information to respond to and fulfill orders, improve Our product and service offerings, communicate with You and with Our Partners, tailor Our marketing efforts, and for internal reporting purposes.
· Inferences from the information listed above. We will use the information listed above to draw inferences about Your preferences to help Us provide You with personalized content and marketing offers and help Us develop and provide better products and services.
· Audio and Visual Information. We may receive digital photos You submit to Us. We use these photos to establish and manage Our customer relations and customer service, and may include photos in Our marketing materials with Your consent. We record customer service telephone calls for quality purposes, to meet Our legal obligations and to enforce Our rights.
· Signatures. We may collect Your signature and related authentication details in connection with any documents You electronically or physically sign and provide to Us. This information may be used to maintain the integrity of Our processes, enforce rights, prevent fraud, or validate Your identity.
· Privacy Choices. We receive and retain information on any opt outs or other choices related to how We collect, use, and disclose personal data.
2. From Contractors and Technicians. We may receive Your commercial information, communications and content, and job photographs and activity descriptions from contractors and technicians when they provide products and services to You. We use this information to provide and improve Our products and services (including by monitoring and reporting the performance of contractors and technicians), to respond to and fulfill orders, and to perform customer service.
3. From Our Partners. We work with Partners to offer products and services, and We may receive Your personal identifiers and commercial information from them so that We can send You offers of Our products and services, enroll You in a service, respond to Your claims, provide You with Our products and services, and for other business and commercial purposes.
4. From Providers of Credit Services. We may receive personal identifiers and commercial information (such as, credit information) and other personal data listed above from credit service providers. We use this information to send offers of Our products and services, provide and improve Our products and services, and to respond to and fulfill orders.
5. From Others. We may receive personal identifiers and professional and education information from data providers to help Us contact You to offer Our products and services that We think may interest You.
6. Automatic Collection through Our Websites. We and Our third-party marketing partners, such as advertising networks, social media platforms and analytics providers, may automatically collect categories of personal data using cookies and similar technology when You use the Websites and receive Our emails. We use this information to provide and improve Our products and services, tailor Your experience on the Websites and Our marketing efforts, and create aggregate internal reports on website usage and activity. These additional categories of automatically collected data may include:
· Online identifiers. We may collect Your IP address and other device and online identifiers when You use Our Websites.
· Geolocation Information. We may use Your IP addresses to estimate an approximate location of the device You are using to access Our Websites to enhance and personalize the features and functionality of Our Websites and product and service offerings.
· Website activity information. We may monitor and collect website activity information and device information, such as website clicks, content and page views, the website each visitor visited prior to Our Websites, domain type, browser version, and internet service provider.
· Inferences from the information listed above. We may use the information listed above to draw inferences about Your preferences to help Us provide You with personalized content and offers and help Us develop and provide better products and services.
7. Anonymous or Aggregated Information. We may de-identify or aggregate data We receive and may use and disclose it for any business purpose as permitted by applicable law.
8. Data Retention: We retain all categories of data listed above until You ask Us to delete Your personal data, as applicable and required by relevant consumer privacy laws and regulations.
Personal Data Disclosure
We may share any of the personal data We receive (listed above) for Our business and commercial purposes and as more specifically described below, including to comply with legal obligations and for auditing, security, and anti-fraud purposes.
Service providers. We may share any of the personal data described above with service providers (including, but not limited to, home service contractors, mailing vendors, service-related technology providers, marketing agencies, payment processors, enrollment fulfillment and survey administrators) that provide services to You and Us. For example, We may provide Your personal identifiers and job request information to home service contractors so they can provide their services to You; We may provide Your personal identifiers to print and communications vendors so that they can send You communications on Our behalf; and We may also provide personal data, including personal identifiers, commercial information, and device and IP address information to Our service providers for fraud detection purposes. We require that service providers use personal data only for the specific purposes specified in Our agreements with them and adhere to security safeguards consistent with applicable law.
Other third parties providing services to Us. We also may share personal data (including Your personal identifiers) with third parties to help Us provide products and services to You and to tailor marketing to Your interests, and target advertising to You on third-party online advertising and social media platforms.
Partners. We may share Your personal identifiers and commercial information (the products and services You have purchased from Us) with Partners, including Your utility company, so that We can manage Your account, facilitate billing, and provide You with Our products and services. We will provide Your personal identifiers and financial information to a payment processing vendor to complete a transaction You have requested. In these situations, You are using and directing Us to intentionally disclose Your personal information (including personal identifiers and financial information) so Our products and services and Your requests can be provided to You.
Affiliates. We may also share any of Your personal data within Our group of companies* that operate in the United States and Canada for the purposes described above. By providing Your personal data to Us, You fully understand and clearly consent to such use and transfers as set out in this Policy.
Business Transactions. In the event of a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets (whether by private sale, through operation of law, as part of a divestiture plan, or otherwise), We will provide Your personal data and transaction history associated with each relevant business unit to the persons and/or entities assuming control of such business unit or the assets or as otherwise necessary to assess and complete the transaction as permitted by law or contract, and they will be able to handle the personal information as stated in this Policy.
We are committed to protecting the personal data You share with Us. In order to prevent unauthorized access, use or disclosure of Your personal data, We have put in place a robust security program which meets or exceeds industry standards and best practices, and leverages technologies, processes, procedures, standards and frameworks to keep information safe and secure. We strictly adhere to a defense in depth methodology which uses multiple layers of security controls to prevent the failure of one control negatively impacting Our overarching security posture. This includes securing Our physical data as well. We utilize many world class technologies to prevent, detect and respond timely to a security event or potential security incident should one occur.
Transmission of information on the internet is not completely secure and therefore We cannot guarantee the security of the personal data sent to Us electronically on Our Websites or otherwise; transmission of such personal data is therefore entirely at Your own risk.
Cookies, Web Beacons, And Other Similar Technologies
Like most websites, We and other companies use browser “cookies,” log files, beacons, pixels, and similar technology on Our Websites and in Our emails. Cookies and similar technology may collect Your personal identifiers (such as IP address, device and browser identifiers and characteristics, and other identifiers), information about Your device (such as operating system, browser characteristics, and language preferences), and Your usage activity on the Websites (such as Your interaction with Our Websites, the link You used to reach them, and the content and advertising displayed on them and Our content and advertising on other websites and online services). Third parties may also collect this personal information from Our websites.
Online Advertising and Usage Analytics
We use third-party advertising services to serve ads when You visit some of Our Websites and other websites, online and social media services, third-party email services to send informational and marketing emails, and third-party analytics services to help Us understand and improve the usage of the Websites and Our email. These services will collect Your personal identifiers (such as, IP address, deviceID, and cookie information, among others), device characteristics (such as, browser version), and website browsing activity from You when You visit the Websites by placing cookies and using other similar technology. The third-party advertising services use that information to provide advertisements to You on Our Websites, other non-affiliated websites or platforms and/or to provide analytical information for Our Websites; they also may collect and combine information about Your online activities over time, on other devices, and on other websites or online services, if those websites and online services also use the same partners.
We currently use Google Analytics to collect and process certain usage data on Our Websites. To learn more about Google Analytics and how to opt out, please visit https://policies.google.com/technologies/partner-sites. You may learn more about advertising networks and opt out of receiving personalized advertisements on this browser or device from advertisers who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt out options of each of those organizations. Links to those sites are here:
Network Advertising Initiative: https://optout.networkadvertising.org/?c=1
Digital Advertising Alliance:
U.S. - https://optout.aboutads.info/?c=2&lang=EN
Canada - http://youradchoices.ca/
When You opt out of personalized advertising, You may continue to see online advertising on the Sites and/or Our ads on other websites and online services, however, such ads will not be personalized to you.
We may use a number of third-party services on Our Websites including Google for Website tag management.
For an understanding of Google’s privacy practices see https://policies.google.com/privacy?hl=en#infocollect.
Third Party Websites and Interaction
Unsubscribe, Privacy Rights, Access Questions, and Further Information
If You wish to exercise any of Your privacy rights under applicable privacy data and protection laws effective in Your state of residence, please contact Us as set forth below under the “Contact Us” heading. Among other things, at Your request and where required by law, We will confirm, delete and/or update the personal data We hold about You, or opt You out of certain data sharing practices. We may have to verify Your identity first.
If You do not want to receive marketing information from Us via email, You may unsubscribe by clicking on the unsubscribe link included in electronic marketing communications. If You do not want to receive marketing information from Us via mail or by telephone You can write, email or call Us using the contact information listed below. If You unsubscribe, You may still receive information from Us but only if it is necessary to provide You with Our products and services, including administrative or transactional messages or satisfaction surveys.
California Privacy Notice and Rights
California consumers have the right to request:
· the deletion of the personal data We have about You, subject to certain exceptions;
· to know what personal information We have collected about You, including categories of personal information, sources, commercial purpose for collecting, sharing or selling personal information about You, categories of third parties to whom We have disclosed personal information, and specific pieces of information We have collected about You correction of the personal data We maintain about You;
· to opt out of the “sale” of personal data; and
· to opt out of the sharing of personal data for cross-contextual behavioral advertising.
California consumers also have the right not to receive discriminatory treatment if they exercise the rights listed above.
You may submit a privacy rights request to Us by:
· Visiting homeserve.com/sc/dataprivacy
· Calling Us toll-free at 833-950-0094 (during regular business hours)
· Submitting a data access request through our webform.
· Submitting an opt out request through Our webform and managing Your cookie settings
When You make a data access request to delete, know or correct Your personal data, We require You to provide information and follow procedures so that We can verify the request and Your jurisdiction or state of residence before responding to it. The verification steps We take may differ depending on Your request and depend on receiving complete and accurate information from You. We will ask You to provide Your full name, address, phone number, email address and HomeServe customer status, as well as select which data access request You are making. Please provide as much of the requested information as possible to help Us verify the request. We will only use the information received in a request for the purposes of responding to the request.
We will match the information that You provide in Your request to information We already have on file to verify Your identity. If We are able to verify Your identity, We will process Your request. If We cannot verify Your identity, We may ask You for additional information to help Us verify Your identity and fulfill Your request.
Once We have verified Your identity, We will fulfill Your request. For a request to delete, We will delete Your personal data, subject to certain exceptions permitted by law, and We will confirm Your request is completed by email. For requests to know what personal data We maintain, after verification of Your identity We will provide You with that information by email. For requests to correct inaccurate personal data, once We verify Your identity, We will respond to You through email and request You to provide direction on what personal data You are requesting be corrected. Once We receive Your response, We will correct Your personal data in Our records and notify You that Your request has been completed through email.
California law permits California consumers to use an authorized agent to make privacy rights requests. An authorized agent must follow the process described above to make a request, and We may additionally require the authorized agent to verify his/her own identity and confirm his/her authority with the California consumer about whom the request was made.
California Notice of Right to Opt Out of Sale and Sharing
As a California consumer, You have the right under the CPRA to opt out of the sale and sharing of Your personal data. California law defines the “sale” of data as sharing or providing a consumer’s personal information to a third party for monetary or other valuable consideration. The CPRA defines sharing as providing personal information to a third party for cross-contextual behavioral advertising purposes. We do not sell Your data in exchange for monetary compensation, but do provide personal information to online advertising platforms for the purposes of cross-contextual behavioral advertising to target Our advertising to You on third-party platforms. You can opt out of these data sharing practices by submitting a request through this webform and adjusting Your cookie settings. Both actions are required to fully opt out of the sale and sharing of Your personal data.
The categories of personal information shared or “sold” to third parties and the categories of third parties to whom the information was sold or shared are as follows: Online and Personal Identifiers (including unique IDs based on device and IP address), name, email address, phone number, zip code are shared with advertising companies and social media platforms for cross-contextual behavioral advertising purposes.
Opt Out Preference Signals: Our Websites respond to browser opt out preference signals sent through a browser connected with a specific device. If You have an opt out preference signal enabled for Your browser and specific device, Your personal data will not be accessed by or shared through cookies and pixels on Our Websites. If You are a HomeServe customer and have a customer account with Us, to fully opt out You must also submit an opt out request through Our online webform in addition to relying on Your enabled opt out preference signal.
We do not collect, use or share sensitive personal information as defined by the CPRA.
We do not have actual knowledge of selling or sharing the personal information of consumers under 16 years of age.
Virginia Privacy Notice and Rights
Pursuant to the Virginia Consumer Data Protection Act (“VCDPA”), Virginia residents have the right to:
· delete the personal data We have collected from or about You;
· access a copy of the personal data We have about You;
· correct inaccurate personal data We have about You;
· appeal a decision to not take action on a data access request; and
· opt out of the sharing of Your data for the purposes of targeted advertising, the sale of personal data or profiling in furtherance of decisions that produce legal or similarly significant effects concerning You.
As a Virginia resident, You may exercise Your privacy rights by:
· Visiting homeserve.com/sc/dataprivacy
· Calling Us toll-free at 833-950-0094 (during business hours)
· Submitting a data access request through Our webform.
· Submitting an opt out request through Our webform and managing Your cookie settings
Virginia Notice of Right to Opt Out
As a Virginia consumer, You have the right under the VCDPA to opt out of the processing of Your personal data for targeted advertising. We process personal data for targeted advertising purposes through cookies and pixels on Our Websites and by sharing personal data with online advertising and social media platforms. To opt out of targeted advertising, You must submit a request through Our webform and manage Your cookie settings.
As a Virginia consumer, You have the right to opt out of the sale of Your personal data. We do not sell Your data to any third parties in exchange for monetary compensation.
As a Virginia consumer, You have the right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer. We do not engage in profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer. For inquiries about such requests, please reach out through email, phone, or mail listed below under “Contact Us.”
Virginia Right to Appeal
As a Virginia consumer, You have the right to appeal Our refusal to take action on a data access request by submitting a request to appeal through this webform or through any means listed under the “Contact Us” section below. Within 60 days of receipt of an appeal, We will inform You in writing via email of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.
Privacy Rights of Nevada Residents
We do not sell personal data for monetary consideration. However, if You are a Nevada resident, You have the right to submit a request directing Us not to sell Your personal data. To submit such a request, please contact Us using the information in the “Contact Us” section below.
If You wish to update Your personal data, or have any questions, comments or complaints about this Policy, or if You wish to opt out of receiving marketing information from Us, please contact Us at:
HomeServe USA Corp.
ATTN: Privacy Officer
601 Merritt 7, 6th Floor,
Norwalk, CT, 06851
You may also update Your online account information by visiting Our Website and logging into Your account.
Our Website is designed and intended for those who have reached the age of majority (18 or 19 years of age, depending on Your jurisdiction of residence). By using Our Website, You affirm that You are at least the age of majority in Your jurisdiction of residence. We are not liable for any damages that may result from Your misrepresentation of age.
No one under the age of 13 is authorized to submit any information, including personal data, on Our Website. Under no circumstances may anyone under the age of 13 use Our Website. Parents or legal guardians of children under 13 cannot agree to these terms on their behalf. We will not knowingly collect any personal data from children under the age of 13. If You become aware that a child has submitted their personal data to Us in a manner that is inconsistent with this paragraph, please contact Us and We will delete such information.
*HomeServe USA Corp. Affiliates and Entities include Service Line Warranties of Canada, Inc., HomeServe USA Repair Management Corp., HomeServe USA Energy Services LLC, Service Line Warranties of America, Inc.; C.M.H., Inc. d/b/a Cropp Metcalfe Air Conditioning and Heating